Privacy Policy

This policy on the protection of privacy specifies the rules for processing and protecting the data of users of the website: www.robotgentleman.com (the “Site”). By using the Site, users can become acquainted with information about the subject of the business activity of the company Robot Gentleman sp. z o.o. with its registered office in Poznań (further: “Robot Gentleman” or the “Data Controller”) and the games offered by Robot Gentleman, and can sign up to receive the company’s newsletter.

This policy on the protection of privacy contains provisions on the personal data of Users of the Site, people who agree to receive the newsletter, people following Robot Gentleman on social media, and those sending questions to the contact mailbox of Robot Gentleman.

The information provided on the Site is verified for correctness. The Data Controller reserves the right to change both the contents of the Site and this policy.

Robot Gentleman is a service provider providing users with services by electronic means involving providing access to the contents of the Site and enabling the use of its features.

I. Information regarding the processing of personal data

1. Identity of the personal data Data Controller

The Data Controller of personal data of users of the Site, people following Robot Gentleman on social media and those sending questions to the contact mailbox (the “Users”) is Robot Gentleman spółka z ograniczoną odpowiedzialnością with its registered office in Poznań (61-758) at ul. Garbary 64, entered into the register of entrepreneurs of the National Court Register (KRS) maintained by the District Court for Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division of the National Court Register under number KRS 0000582435, NIP (Tax ID No.): 9721258348, REGON: 362811241, share capital: PLN 5,000,00.

For matters regarding personal data, the Data Controller can be contacted by e-mail at:hello@robotgentleman.com, writing “personal data” in the subject line or by letter sent to the following address: Robot Gentleman sp. z o.o. with its registered office in Poznań, ul. Garbary 64, 61-758 Poznań, with the annotation “personal data” on the envelope.

2. the purpose of processing personal data

I. The data of Users of the Site is processed for the purpose of ensuring the proper functioning of the Site, i.e., displaying the contents of the Site, in order to maintain a session on the Site, ensure safety, as well as for analytical and statistical purposes, and, if consent is given, for advertising purposes.

II. The data of people sending messages to the contact mailbox are processed in order to respond to a given question.

III. The data of people following Robot Gentleman on social media, interacting with profiles of brands belonging to Robot Gentleman (fanpage brands belonging to Robot Gentleman on the Facebook service, and the Robot Gentleman profile on Instagram, Twitter, LinkedIn, and Discord) are processed for marketing purposes, including providing information about the Data Controller’s professional activity, and responding to questions posed by followers.

IV. The data of people who have subscribed to the Robot Gentleman newsletter are processed for the purpose of sending advertising information and information about the Data Controller’s activities.

3. legal basis for processing personal data

I. The basis for processing the data of Users using the Site’s features is the necessity of performing the agreement (for the provision of electronic services) to which the person whose data are processed is a party, or performing acts at the request of a person to whom the data relate before entering into an agreement (legal basis: Art. 6, sec. 1, ltr. b) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – further: the “GDPR”). The above services (provided under the agreement for the provision of electronic services) are free of charge and their provision begins at the moment when a User visits the Site and, depending on which features of the Site are used, include browsing the contents available on the Site (including on all subpages) and watching videos available on the Site.

II. The basis for processing the data of people sending questions to the Data Controller’s e-mail inbox is the legally justified interest of the Data Controller in replying to sent messages (legal basis: Art. 6, sec. 1, lit. f) of the GDPR).

III. The data of people who subscribed to the newsletter are processed based on consent for the processing of personal data expressed for this purpose by the person to whom the data relate, consent to receiving commercial information directed at a specified recipient who is a natural person with the use of electronic means of communication and consent to receiving marketing information directly aimed at telecommunications equipment (legal basis: Art. 6, sec. 1, lit. a) of the GDPR, Art. 10 of the Act on Providing Services by Electronic Means and Art. 172 of the Telecommunications Law).

IV. The basis for processing the data of people who follow Robot Gentleman on social media and interact with its profiles, including by adding comments, liking posts or sending messages, is the legally justified interest of the Data Controller in conducting marketing for its own brands (legal basis: Art. 6, sec. 1, lit. f) of the GDPR).

V. The basis for processing data collected with the use of cookie files and used for analytical and statistical purposes and collected with the use of tools offered by Google and HotJar is the consent for Robot Gentleman to analyze the activity and behavior of Users of the Site and creating analytical and statistical studies on that basis in order to optimize the usefulness and attractiveness of the Site (legal basis: Art. 6, sec. 1, lit. a) of the GDPR).

VI. Data collected with the use of cookie files, used for advertising purposes and collected with the use of tools available through the Google platform (and services such as Google Analytics and Google Ads) and Albacross, as well as Facebook Pixel, are processed on the basis of the voluntary consent of the user. When such consent is given, the processing involves the automated profiling of the User’s data by registering the browsing history of a given page, and thereby monitoring the User’s interests and location with the help of cookie files (legal basis: Art. 6, sec. 1, lit. a) of the GDPR).

4. Information on the recipients of personal data and transfer of data to third parties

the site

I. Recipients of data (meaning the entities to whom data can be disclosed) can be entities from the following categories: entities and bodies to whom personal data are provided based on universally binding provisions of law or entities performing services for Robot Gentleman, including IT (hosting) and legal services.

II. Data of Users who have not objected to the processing of data for analytical and statistical purposes and those who have consented to the processing of data for advertising purposes, collected with the use of tools offered by Google when entering the Site, will be entrusted to companies from the Google group (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA). Please read the following document to receive detailed information regarding this entity’s policy for processing personal data in connection with those features: https://support.google.com/displayvideo/answer/7621162?hl=pl&ref_topic=3528231.

III. Data of Users who have not objected to the processing of data for analytical and statistical purposes, collected with the use of tools offered by HotJar when entering the Site, will be entrusted to the company HotJar (HotJar Ltd., Dragonara Business Centre 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta) in order to apply the HotJar tools on the Site. Please read the following document to receive detailed information regarding this entity’s policy for processing personal data in connection with those features:

https://help.HotJar.com/hc/en-us/articles/360039027113-Processing-Personal-Data-in-HotJar.

IV. Data of Users who have consented to the processing of data for advertising purposes, collected with the use of tools offered by Facebook when entering the Site, will be entrusted or disclosed to Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. If the User consents, information about his/her activity on the Site, including information about devices visited through the Site and the manner of using the services, will be transferred to the above entity regardless of whether the User has a Facebook account and whether he/she is logged on to Facebook. More information on how Facebook uses cookie files in connection with Facebook’s business tools can be found in the Facebook Cookies Policy (https://www.facebook.com/policies/cookies).

V. Data of Users who have consented to the processing of data for advertising purposes, collected with the use of tools offered by Albacross when entering the Site, will be entrusted or disclosed to Albacross Nordic AB Company reg. No. 556942 – 7338, Tegelbacken 4A, 111 52 Stockholm, Sweden. Please read the following document to receive detailed information regarding this entity’s policy for processing personal data in connection with those features:

https://albacross.com/privacy-policy/.

VI. In the above cases (II – V) personal data may be transferred to third countries (recipients in third countries). According to information obtained from the above-mentioned entities, data can be transferred to third countries that the European Commission has confirmed provide the relevant degree of protection as well as third countries which the European Commission has not confirmed provide the relevant degree of protection; however, in such cases the relevant security is applied under standard contract clauses in compliance with the relevant decisions, in particular Commission implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. In such cases, copies of the above-mentioned security can be obtained upon a request from the entity to whom data are transferred.

Newsletter

The data recipient will be the entity providing hosting services for the Data Controller and the entity supplying the Amazon SES tool, which is used for mailing packages, i.e., Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg. Please read the following document to receive detailed information regarding this entity’s policy for processing personal data in connection with those features:

https://aws.amazon.com/privacy/?nc1=f_pr.

In the above case, personal data may be transferred to third countries (recipients in third countries). According to information obtained from the above-mentioned entities, data can be transferred to third countries that the European Commission has confirmed provide the relevant degree of protection as well as third countries which the European Commission has not confirmed provide the relevant degree of protection; however, in such cases the relevant security is applied under standard contract clauses in compliance with the relevant decisions, in particular Commission implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. In such cases, copies of the above-mentioned security can be obtained upon a request from the entity to whom data are transferred.

social media

Access to the contents of sent messages, comments made, and reactions to content published by Robot Gentleman will have social media providers on which the profile of the Robot Gentleman brand can be found and with which a given person interacted. To receive detailed information regarding the policy of the provider of a given platform for processing personal data, please read the privacy policy of such entity:

Facebook

Provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

https://www.facebook.com/privacy/explanation/

Instagram

Provider: Meta Platforms Ireland Ltd. 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland

https://help.instagram.com/519522125107875/?maybe_redirect_pol=0

Twitter

Provider: Twitter International Company, 1 Cumberland St. S, Fenian St., Dublin 2, D02 AX07, Ireland

https://help.twitter.com/pl/rules-and-policies/twitter-rules 

LinkedIn:

Provider: LinkedIn Ireland Unlimited Company, 70 Sir John Rogerson's Quay, Dublin 2, Ireland

https://pl.linkedin.com/legal/privacy-policy

Discord:

Provider: Discord Netherlands BV, Schiphol Boulevard 195, 1118BG Schiphol, Netherlands

https://support.discord.com/hc/pl/sections/115000344951-Polityka-prywatno%C5%9Bci

In the above cases, personal data may be transferred to third countries (recipients in third countries). According to information obtained from the above-mentioned entities, data can be transferred to third countries that the European Commission has confirmed provide the relevant degree of protection as well as third countries which the European Commission has not confirmed provide the relevant degree of protection; however, in such cases the relevant security is applied under standard contract clauses in compliance with the relevant decisions, in particular Commission implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. In such cases, copies of the above-mentioned security can be obtained upon a request from the entity to whom data are transferred.

5. the period for which personal data will be stored

I. User data collected when a User browses the Site are processed in accordance with the table for applying cookie files (see below), however, no longer than until the User cleans the contents of cookie files from the browser the User uses. User data are collected and analyzed using cookies. In this regard, data collected using the tools available through Google, HotJar, Albacross, and Facebook are processed until the moment settings are changed by resigning from the possibility of collecting data with the use of cookies.

II. In other cases, User data will be stored by the Data Controller for the following periods:

1. when data is processed in connection with the performance of a contract -- until the contract’s termination date, and then in a limited scope for the period indicated in letter b below;
2. data processed in the scope of determining and pursuing the Data Controller’s claims or defense against notified claims – until the time potential claims are barred by the statute of limitations;
3. when consent has been given for the processing of personal data – for the time necessary to achieve the purpose of the consent or its withdrawal by the User, whichever occurs first;
4. when data are processed on the basis of a legally justified interest of the Data Controller – until the User objects to the processing of the data, unless the Data Controller demonstrates that it has a legal interest superior to the User’s legal interest in the further processing of such data. If the User expresses an objection to the processing of data for marketing purposes, the objection will always be considered in accordance with the request of the person to whom the data relate;
5. if data are processed in connection with e-mail correspondence conducted with the User, the will be processed for the period of three months from the end of the correspondence.

6. rights of the data subject

The persons whose data are processed have the following rights:

1. the right of access to personal data and the right to obtain a copy of such data,
2. the right to request the rectification (correction) of personal data,
3. the right to request the removal of personal data,
4. the right to the limitation of the processing of personal data;
5. if data is processed on the basis of consent or an agreement, the person whose data are processed also has a right to transfer personal data;
6. if data are processed on the basis of a legally justified interest of the Data Controller or by a third party, the persons whose data are processed have a right to raise objections to such processing;
7. if the Data Controller processes personal data based on consent, the person whose data are processed has a right to withdraw the consent at any time and in any manner, without affecting the legality of the processing performed pursuant to the consent before its withdrawal;
8. the person whose data are processed also has a right to raise complaints to the supervisory authority, which is the President of the Personal Data Protection Office.

7. Information on whether the provision of data is a statutory/contractual requirement and the consequences of not providing data

Providing personal data is voluntary (it is not a statutory requirement), but in the relevant scope it is a condition for entering into a contract or a contractual requirement for a contract on the provision of  services by electronic means, which means it is essential for using the Site. Whenever the Data Controller requests consent for the processing of personal data, the lack of such consent means the Data Controller cannot collect such data.

8. browsing the site and subpages

Browsing the Site requires the mandatory disclosure to us of the IP address and personal data collected using cookie files and other technology placed by the Site on the device used by the User. On the basis of that information it is possible to, among others, specify the country and the telecommunication operator used by a given User to connect with the Site. The Site automatically obtains the following data: the User’s IP address, information on the computer and connection, the type of browser and version, the types and versions of plugs for browsers and the operating system.

In addition, however, only if the browser settings are not changed, the Site gathers additional data regarding visited web pages such as: the number of visits, the country, the browser, the time of the visit, the manner of moving around the Site, etc., which are analyzed using tools offered by Google and HotJar, which help us understand how Users use the Site. That information is used solely for collective, anonymous statistical and analytical studies, which enables us to improve the products and client services of this Site.

If a User consents, the gathered data is also used for marketing and advertising purposes through the tools Facebook Pixel and Albacross in order to direct other advertisements to the User via other sites and portals, as well as using the tools offered by Google, with the aim of using remarketing tools. Data processed for marketing and advertising purposes is used to analyze how you use the Site and to monitor conducted advertising activity.

9. safety of collected data

Personal data and other, impersonal data gathered via the Site are stored on a secure server, and only authorized personnel have access to the data. Such personnel have been trained in the area of protection of personal data and IT system security, and are obligated to maintain strict confidentiality. Personal data are processed while maintaining technical and organizational measures ensuring the protection of processed data in accordance with the requirements specified in regulations on the protection of personal data. The measures securing data have been adjusted to the requirements of the GDPR.

II. cookies

Certain elements of the Site may use cookies, which are small files stored on the User’s browser. They permit the storage of additional data related solely to the User. Such files allow the identification of the User and permit websites to be adapted to the User, as well as speed up certain operations. Cookies can be saved only for the time when a website is visited (a session) or for a specific time indicated in advance. The Site uses the following cookies:

The User can limit the Data Controller’s access to cookies at any time. To do so, the User should change the settings of his/her internet browser. Changing the settings, however, may lead to the improper functioning of the Site on the device currently used by the User and in extreme situations may even result in the total inability to use the Site.

The User can disable cookies by changing the browser settings. The relevant option is most often found in the privacy bookmark or in the settings of a given program. 
Below is information on how to change the cookie settings in the most popular internet browsers: 

1. for Mozilla Firefox at the address: https://support.mozilla.org/pl/kb/blokowanie-ciasteczek 
2. for Internet Explorer at the address: http://windows.microsoft.com/pl-pl/windows-vista/block-or-allow-cookies
3. for Microsoft Edge browsers at the address: https://privacy.microsoft.com/pl-PL/windows-10-microsoft-edge-and-privacy
4. for Google Chrome browers at the address: https://support.google.com/chrome/answer/95647?hl=pl
5. for Opera browers at the address: https://help.opera.com/pl/latest/security-and-privacy/
6. for Safari browsers at the address: https://support.apple.com/pl-pl/guide/safari/sfri11471/mac.

Changing the settings by resigning from the possibility of collecting data with the use of Google, HotJar, Albacross or Facebook tools should not in any way limit the ability to use the Site.

Last updated December 8, 2023