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Privacy Policy

Effective Date: August 1, 2020

  1. INTRODUCTION

This Privacy Policy describes how KATNAPPE SP. Z O. O. (“KATNAPPE,” “we,” “us” or “our”) collects, uses, and shares information about you and applies to your use of any online service location, including our websites, apps, and games, that posts a link to this Privacy Policy and all features, content, and other services that we own, control and make available through such online service location (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection) or the information collection activities of other parties, such as platform providers.

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below. If you are a California resident, Nevada resident, or data subject in Europe, please see the additional disclosure sections below.

1.1 GOVERNING LAW

For users resident in the European Union and elsewhere in the world (but not the USA):

You and we agree that your use of KATNAPPE games and services, and this Agreement, will be governed by and interpreted according to the laws of Poland and any dispute regarding it will be exclusively under the jurisdiction of the courts of Poland. In any legal claim under this Agreement, the side, which wins will be entitled to its legal fees and expenses.

For users resident in the USA:

You and we agree that your use of KATNAPPE games and services, and this Agreement, will be deemed to be entered into in Los Angeles, California and governed by and interpreted according to the laws of the State of California, USA (and, if applicable, US Federal law). Any legal claim by you against CD PROJEKT RED will be made exclusively in state or federal court located in Los Angeles, California, which will have subject matter jurisdiction regarding the dispute between you and us and therefore we both consent to the exclusive jurisdiction of those courts. In any legal claim under this Agreement, the side, who wins will be entitled to its legal fees and expenses.

  1. INFORMATION COLLECTION
  2. Information You Provide

We and our Service Providers (defined below) collect information you provide directly via the Service. For example, we collect information when you register an account with us, post in our forums, play our games, communicate with us or other users, or interact with us through the Service. The categories of information we collect and have collected in the last twelve (12) months include:

  • Contact Data, including your first and last name, email address, postal address, and phone number.
  • Account Credentials, including your username, password, password hints, and information for authentication and account access. 
  • Demographic Data, including your gender and location. 
  • Profile Data, including your interests and preferences.
  • Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in our forums). 
  • Job Applicant Data, including your employment history, cover letter, transcript, writing samples, references and other data as necessary to consider for you for a job opening if you submit an application to us.

You may choose to voluntarily submit certain other information to us through the Service, but you are solely responsible for such information in instances where we have not requested that you submit such information to us.

Certain areas of the Service, such as our forums, and are designed to help you share information with the world. If you make information public through our Service, your rights with respect to such information may be limited. Please think carefully before making information public. You are solely responsible for information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below. 

  1. Information Collected Automatically

We and our Service Providers may automatically collect certain information about your device and how your device interacts with our Service and other services. The categories of information we may automatically collect and may have collected in the last 12 months include: 

  • Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view, the time of day you browse, and your referring and exiting pages.
  • Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers. 

We use various current – and later – developed technologies (“Tracking Technologies”) to collect this information including the following:

  • Log Files: Log files are files that record events that occur in connection with your use of the Service.
  • Cookies: A cookie is a small text file that is stored on a user’s device, which may be a session ID cookie or a persistent cookie. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. 
  • Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages, emails, and advertisements. Web beacons are often used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, customize content, bring you advertising, and provide you with additional functionality.
  • Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or another party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.
  • In-App/Game Technologies: There are a variety of tracking technologies that may be included in apps and games, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app/game and to track user activity across apps/games. We may incorporate technologies from separate entities that allow us to track our conversions, customize content, bring you advertising, and provide you with additional functionality.

For further information on how we use Tracking Technologies for analytics and advertising, and your rights and choices regarding them, see the “Technology Integrations, Analytics, and Advertising” and “Your Rights and Choices” sections below.

  1. Information from Other Sources

We also collect information from other sources. The categories of sources from which we collect and have collected information in the last 12 month include: 

  • Social networks when you engage with our content, reference our Service, or grant us permission to access information from the social networks.
  • Partners and Retailers that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publishers and Platforms, such as Microsoft, Sony, Valve, and Google, and their affiliates, including information about your purchase and use of games. 
  • Publicly-available sources, including data in the public domain. 
  1. USE OF INFORMATION

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes  for collecting and using information, including in the last 12 months, include to:

  • Operate and manage our Service, including our websites, forums, apps, and games;
  • Process and facilitate your communications and transactions;
  • Respond to your comments, questions, and requests, and provide customer service;
  • Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  • Prevent and address fraud, breach of policies or terms, and threats or harm;
  • Monitor and analyse trends, usage, and activities;
  • Conduct research, including focus groups and surveys;
  • Improve the Service or other KATNAPPE websites, applications, marketing efforts, products and services;
  • Send you advertisements and communicate with you regarding our and other party products, services, offers, promotions, rewards and events we think you may be interested in; and
  • Fulfill any other business or commercial purpose at your direction or with notice and your consent. 

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

  1. SHARING OF INFORMATION

We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information in the last 12 months, include the following: 

  • Service Providers. We share information with agents, vendors, consultants, and other entities that process information on our behalf (“Service Providers”). For example, we may engage Service Providers to operate or host parts of the Service, provide services related to the online components of our apps and games, assist with our Promotions (defined below), or provide analytics or marketing services. These Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes. 
  • Partners and Retailers. We share information with partners and retailers in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
  • Publishers and Platforms. We may share information about you with publishers and platforms (such as Microsoft, Sony, Valve, and Google), and their affiliates, in connection with providing you with our Service and facilitating your requests. For more information about how these publishers and platforms handle information about you, please refer to their respective privacy policies and terms of use. 
  • Vendors and Other Parties. We share information with vendors and other parties for business and commercial purposes, including analytics and advertising technology companies. Vendors and other parties may act as our Service Providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below. 
  • Affiliates. We share information with our affiliates for internal business purposes.
  • Protection of Rights. We must disclose information about you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share information about you to: (i) comply with any applicable law, regulation, or legal process, such as a court order or subpoena; (ii) detect, prevent, or otherwise address fraud, security or technical issues associated with the Service or violations of our Terms of Use, or (iii) protect the rights, property or safety of KATNAPPE, its employees, clients, or users of the Service or others.
  • Asset Transfers. We may share information about you in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Facilitating Requests. We share information at your request or direction.  
  • Consent. We may share information about you with notice to you and your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose, except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

  1. SWEEPSTAKES, CONTESTS, AND PROMOTIONS

We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by other parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information may be disclosed to other parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

  1. Technology Integrations, Analytics, and Advertising

Our Service may contain content from and hyperlinks to websites, locations, platforms, and services operated and owned by other parties. In addition, our Service may contain features that allow you interact with, connect to, or access our Service through certain other platforms and devices. For example, we may offer our games on other platforms and/or devices such as Xbox, PlayStation, Steam, and Stadia, or allow you to broadcast your videos over video platforms, such as Twitch. When you interact with another platform or device, other parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you connect the Service with another service, both we and the applicable service may have access to and use information associated with your use of such connectivity feature. 

Our Service also may contain Tracking Technologies, some of which are owned and operated by other parties. For example, we may use analytics services, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, we may work with agencies, ad networks,  advertisers, and other parties to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on another service or device after you have left the Service (“Interest-based Advertising”)

Please note that when you interact with other entities, including through Tracking Technologies or when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by other parties, whether through our Service or another service, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use. 

For further information on Tracking Technologies and your choices regarding them and for analytics and advertising, please see the “Information Collected Automatically” section above and the “Your Rights and Choices” section below.

  1. YOUR RIGHTS AND CHOICES
  2. Account.

You have the right to access information that you have voluntarily submitted to us through your account, including correcting, updating, or removing information, by sending an email to us at [email protected] We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  1. Tracking Technology Choices.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. With respect to our apps, you can stop all collection of information via the app by uninstalling the app. 

Please be aware that if you disable or remove these technologies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what website and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take any action with respect to these “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

  1. Analytics and Interest-Based Advertising.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Some of the advertisers and other parties that perform advertising-related services for us may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). KATNAPPE is not responsible for effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

  1. Communications

You may opt-out of receiving marketing emails from us at any time by following the instructions as provided in marketing emails to click on the unsubscribe link or by sending an email to us at [email protected] with the word UNSUBSCRIBE in the subject field of the email. Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or KATNAPPE’s ongoing business relations.

We may send you push notifications until you remove our apps or games or opt-out by adjusting the permissions on your device.

  1. CHILDREN

The Service is intended for a general audience and not directed to children under thirteen (7) years of age. KATNAPPE does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe KATNAPPE has collected such information in a manner not permitted by COPPA, please email us at [email protected] or send us a letter to KATNAPPE SP. Z O. O. ,Address 1: PANSKA, 96, No. 83, Warsaw, Mazowiecki, Poland [PL], Postal Code: 00-837, and we will remove such data to the extent required by COPPA. We will remove the data to the extent required by applicable laws. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at [email protected] with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. 

We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  1. INTERNATIONAL TRANSFER

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. For personal data transferred from the United Kingdom, the European Economic Area, and Switzerland, we will provide appropriate safeguards, such as through use of standard contractual clauses. 

  1. DATA SECURITY

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through our Service.

  1. CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice, to your email address.

  1. CONTACT US

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

Email Address:

[email protected] 

Mailing Address: 

KATNAPPE SP. Z O. O.

Address 1: PANSKA, 96, No. 83

City: Warsaw

State/Province: Mazowiecki

Postal Code: 00-837

Country: Poland [PL]

  1. ADDITIONAL DISCLOSURE FOR CALIFORNIA RESIDENTS

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. 

  1. Notice of Collection.

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: 

  • Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account. 
  • Demographics, such as your gender. This category includes data that may qualify as protected classifications under other California or federal laws. 
  • Commercial information, including purchases and engagement with the Services.
  • Internet activity, including your interactions with our Service.
  • Inferences, including information about your interests and favorites.

For more information on information we collect, including the sources we receive information from, review the “Information Collection” section above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to provide and manage our Services. 

KATNAPPE does not sell personal information as the term “sell” is defined under the CCPA. 

  1. Right to Know and Delete. 

If you are a California resident, you have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us: 

  • The categories of personal information we have collected about you;  
  • The categories of sources from which the personal information was collected; 
  • The categories of personal information about you we disclosed for a business purpose or sold; 
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold; 
  • The business or commercial purpose for collecting or selling the personal information; and 
  • The specific pieces of personal information we have collected about you.

To exercise any of these rights, please submit a request through our online form, by sending an email to [email protected], or mailing us a letter to KATNAPPE SP. Z O. O. ,Address 1: PANSKA, 96, No. 83, Warsaw, Mazowiecki, Poland [PL], Postal Code: 00-837. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete. If you have a disability and would like to access our Privacy Policy in an alternative format, please contact us at [email protected] You have the right not to receive discriminatory treatment by us for the exercise of any your rights. 

  1. Authorized Agent. 

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. 

  1. Shine the Light. 

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please email us at [email protected] or send us a letter to KATNAPPE SP. Z O. O. ,Address 1: PANSKA, 96, No. 83, Warsaw, Mazowiecki, Poland [PL], Postal Code: 00-837. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that KATNAPPE is not required to respond to requests made by means other than through the provided email address or mail address.

  1. ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at [email protected]

  1. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE
  2. Roles.

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). GHM acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.

  1. Lawful Basis for Processing.

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. 

  1. Privacy Shield. 

KATNAPPE complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the United Kingdom, the European Economic Area, and Switzerland to the United States, respectively. KATNAPPE has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. KATNAPPE will provide appropriate safeguards to comply with the judgment issued by the Court of Justice of the European Union on July 16, 2020 declaring the EU-U.S. Privacy Shield Framework as invalid. 

In accordance with our obligations under Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, we hereby affirm our commitment to subject to the Privacy Shield Principles all personal data transferred from the United Kingdom, the European Economic Area, and Switzerland in reliance on Privacy Shield. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third party agent to which we transfer your personal data in reliance on Privacy Shield and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.

In the event that you have any inquiry, dispute, or claim arising out of or relating to our reliance on Privacy Shield, please email us at [email protected] or send us a letter to KATNAPPE SP. Z O. O. ,Address 1: PANSKA, 96, No. 83, Warsaw, Mazowiecki, Poland [PL], Postal Code: 00-837. If we are unable to resolve your complaint regarding personal data transferred in reliance on Privacy Shield directly, you may submit your complaint at no cost to you to JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. In the event there are residual complaints that have not been resolved by JAMS regarding personal data transferred in reliance on Privacy Shield, or any other means, you may seek a non-monetary remedy through binding arbitration to be provided to you in accordance with the Privacy Shield Principles.

To learn more about the Privacy Shield Framework, and to view KATNAPPE’s certification, please visit https://www.privacyshield.gov/.

  1. Your Data Subject Rights. 

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

You may exercise your rights by submitting a written request to us at the address set out in the “Contact Us” section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

© 2020  KATNAPPE SP. Z O. O. All rights reserved

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