ANSHAR PUBLISHING PRIVACY POLICY
Last update: March 2024
Anshar Publishing values your privacy and respects your right to control your personal
data. We intend to be transparent about what data we’re collecting and why. We will protect
your data. We do not sell your data to third parties, and we never will.
This statement explains the personal information we collect from and about you, and how
we use it. The statement also covers what choices you can make about the data we collect,
and how you can control those choices. Please read this statement carefully to understand
when you may provide personal information to us and how it will be used by Anshar.
The terms “we”, “us”, or “Anshar” are each intended to refer to Anshar Publishing.
This privacy policy applies to the following situations when your data is collected:
a) visiting our website https://ansharstudios.com/ (“Website”);
b) using our products – games and other products related to the game (“Products”);
c) contacting us using our email or electronic contact form available on the Website or
when we contact you by email;
d) stationary events at which Anshar is an exhibitor or participant (“Stationary
Events”);
e) online events concerning our games or other products, for example involving the
release of a beta version of a game to users (“Online events”).
I. Controller of your data
The controller of your personal data is Anshar Publishing sp. z o.o.
Our corporate details are as follows: registered office in Katowice at J. Gallusa 10, 40-594
Katowice, a company entered into the registry of entrepreneurs of the National Court
Register under the number (KRS): 0000916670, registry documentation is kept by the
District Court for the city of Katowice, VIII Commercial Division of the National Court
Register Tax Identification Number (NIP): 6343000511, share capital: 10.000 zł.
II. Contact details
If you have any questions about the use of your personal data or you want to exercise
your rights regarding your personal data, please contact us using:
a) e-mail address: privacy@ansharpublishing.com;
b) our address indicated in Section I above;
c) electronic contact form available on our Website.
III. Website
When you use our Website we process your personal data (including IP address or other
identifiers and information collected through cookies or other similar technologies) for the
following purposes:
a) to provide services electronically in terms of providing users with access to
content collected on the Website – the legal basis for the processing is the necessity
of the processing for the performance of the agreement for the provision of
electronic services (Article 6 (1)(b) GDPR);
b) for analytical and statistical purposes – the legal basis for the processing is our
legitimate interest (Article 6(1)(f) GDPR), involving analysis of users’ activities, as
well as their preferences to improve the functionalities used and services provided.
IV. Products
When you use our Products we process your personal data for the following purposes:
a) to offer you support in case something goes wrong i.e., respond to reported
problems with our Products, to improve and update our Products, in particular via
Steam or Discord – the legal basis for processing is our legitimate interest (Article
6(1)(f) GDPR) involving improving and ensuring the proper operation of our
Products;
b) to prepare analyses and statistics – the legal basis for processing is our
legitimate interest (Article 6(1)(f) GDPR) involving analysis of your activities to
improve, update and make our Products better over time;
When you use our games we collect data about your playing session, but we
compare and analyze it only after proper anonymization (that means that the set
of data we use to prepare analyses and statistics does not contain any information
that could identify you personally). For this purpose, we use information like your
story decisions, combat decisions, deaths, in-game locations you have visited,
in-game shopping decisions, and your party and character customization decisions.
It does not include hardware or software information, IP address, email address,
usernames, or anything else that does not have anything to do with playing the
game.
V. Contact
On our Website you can find an electronic contact form (“Pitch your game”) to contact us
about our services.
a) Using the form requires providing the personal data necessary to respond to your
question (name and e-mail address). Providing your name and e-mail address is
voluntary, but failure to provide this data will result in the inability to provide you
with the contact form service.
b) You may also provide other data to facilitate contact with you and process the
request (data provided optionally).
You can also contact us or we can contact you (for example if you are our contractor) via
our e-mail address and postal address indicated in Section II above.
When you contact us using our contact form that you can find on our Website, by e-mail,
or by post or in case we contact you by e-mail or by post, we process your personal data
for the following purposes:
a) to identify you as a sender and to handle your request sent via the
electronic contact form – the legal basis for processing is the necessity of
processing to perform the service contract (Article 6(1)(b) GDPR) and – in case of
data provided optionally – our legitimate interest of being able to provide an answer
to a request concerning our activity (Article 6(1)(f) GDPR);
b) to contact you in order to handle your request sent via e-mail or post, to
contact you in connection with our contract or other arrangements, to
conduct further correspondence with you – the legal basis for processing is
our legitimate interest of being able to provide an answer to a request concerning
our activity or other contact request from your side or conclusion or performance of
a contract with a person or entity you represent (Article 6(1)(f) GDPR); in case we
provide you with our correspondence or answer your correspondence in connection
with an agreement to be concluded or that is concluded with you – the legal basis
for processing is the necessity of processing for the performance of the agreement
or necessity to take steps prior to entering into such an agreement at your request
(Article 6(1)(b) GDPR);
c) in case of marketing e-mail correspondence we process you data also to promote
our Products or business activity – in such a case the legal basis for processing
is our legitimate interest (Article 6(1)(f) GDPR) in connection with your consent to
receive such a correspondence (we will send you marketing information by e-mail
only after you give your consent for such a mailing).
VI. Events
When you participate in our Stationary Events and Online Events, we may process your
personal data for the following purposes:
a) in case you fill out the questionnaire provided by us about our Products – to create
analysis and statistics – the legal basis for the processing is our legitimate interest
(Article 6(1)(f) GDPR), involving creating analysis and statistics in order to improve
our Products functionality;
b) in case your image is captured in photos of the Stationary Event – to promote our
activities in our social media – the legal basis for the processing is our legitimate
interest (Article 6(1)(f) GDPR) involving promoting and marketing our activities in
connection with your consent to use such image.
VII. Newsletter
If you would like to subscribe to our Newsletter, you need to provide us with your e-mail
address. Providing your e-mail address is voluntary, but failure to provide it will result in
the inability to provide you with our Newsletter. Since our Newsletter may contain and
typically contains marketing content, it may be sent to you only after you agree to such
a subscription.
When you subscribe to our Newsletter we process your personal data (name, e-mail
address) for the following purposes:
a) to provide the Newsletter to you, including to promote our Products and
business activity – the legal basis for processing is our legitimate interest (Article
6(1)(f) GDPR) in connection with your consent to receive such a Newsletter;
b) to create analysis and statistics – the legal basis of the processing is our
legitimate interest (Article 6(1)(f) GDPR), involving conducting analyses of users’
activity on the Website in order to improve the applied functionalities.
VIII. Social media
We may process your personal data when you visit our social media profiles like at:
a) Twitter (https://twitter.com/ansharpublish )
b) LinkedIn (https://www.linkedin.com/company/ansharpublishing/ )
c) Facebook (https://www.facebook.com/ansharpublishing )
d) Youtube (https://www.youtube.com/ansharstudios)
When you enter our social media profiles or use other content provided by us via social
media, we may process your data for the following purposes:
a) to maintain our social media profile, to inform you about Anshar Studios’
activities and promote various events and our Products. The legal basis for
processing of your personal data for this purpose is our legitimate interest (Article
6(1)(f) GDPR) involving promoting our own brand and products.
Facebook plug in
At our Website we use Facebook plug-in. Clicking on it sends you to our Facebook profile.
In such a case your data such as information about the web browser or app used, online
identifiers including IP addresses and, insofar as provided, FB-related identifiers or device
identifiers (such as mobile OS advertising IDs), as well as information on opt-out/limited
ad tracking status are transferred to Facebook. In the scope of this data, Facebook
(company Meta Platforms Ireland Limited) and Anshar are joint controllers in accordance
with Article 26 GDPR.
Information how Facebook processes personal data, including the legal basis Facebook
relies on and the ways to exercise your rights against Facebook, can be found in Facebook’s
Data Policy available at: https://www.facebook.com/about/privacy.
Anshar Publishing and Facebook have entered into Controller Addendum to determine the
respective responsibilities for compliance with the obligations under the GDPR with regard
to the joint processing. You may read the provisions of this addendum available at the link
https://www.facebook.com/legal/controller_addendum.
When you enter our LinkedIn company profile also LinkedIn will process your data provided
to LinkedIn such as job function, country, industry, seniority, company size, and
employment status. Additionally, LinkedIn will process information on how you have
interacted with Anshar Publishing’ company page. In connection with this processing
LinkedIn (LinkedIn Ireland Unlimited Company) with Anshar are joint controllers in
accordance with Article 26 GDPR in regard to data included in page insights provided by
LinkedIn to Anshar. Page Insights provided to Anshar consist of aggregated data and,
LinkedIn will not provide to Anshar your personal data or enable Anshar to link page
insights back to you.
Information how LinkedIn processes your personal data can be found in privacy policy
available at https://www.linkedin.com/legal/privacy-policy?#use.
More detailed information about joint controlling between LinkedIn Ireland and Anshar can
be found in joint controller addendum available at: https://legal.linkedin.com/pages-jointcontroller-addendum
IX. Kickstarter
With the help of the Kickstarter platform, we run campaigns where you can support our
products’ creation. Kickstarter provides us with some of the data you submit through the
Kickstarter platform (your nickname, e-mail address, the amount of your support for our
project, the reward you have selected, other information requested to provide you reward
and traffic analytics about your activity on our project pages). We are a controller of the
personal data that we receive (Kickstarter does not provide us with any of your financial
data, so we do not process this kind of data).
In connection with your participation in the Kickstarter campaign we process your data for
the following purposes:
a) to enable you to back our project and to deliver a reward to you as
promised – the legal basis for processing is a necessity to perform a project
backing agreement (Article 6(1)(b) GDPR);
b) to create analytics and statistics on the activity on our project pages – the
legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) involving
analysis of users’ activities, as well as their preferences in order to improve our
campaigns.
More information you can find in Kickstarter Privacy Policy:
https://www.kickstarter.com/privacy?ref=global-footer .
Your data may be transferred to the Backerkit platform. We use the Backerkit platform as
a tool to manage our projects on Kickstarter and generate analysis and statistics.
Kickstarter on our behalf transmits your data (data we have access to) from the Kickstarter
platform to the Backerkit platform. Backerkit adopts appropriate security measures to
protect your data. More information you can find in Backerkit privacy policy:
https://www.backerkit.com/privacy_policy#:~:text=Privacy%20Policy%20This%20Priva
cy%20Policy%20governs%20the%20manner,and%20all%20products%20and%20service
s%20offered%20by%20BackerKit.
X. Other processing purposes
We may also process your personal data for the following purposes:
a) to comply with legal obligations imposed on Anshar, such as provision of
information and documents required by public administration authorities – the legal
basis for processing is necessity to comply with a legal obligation to which the
controller is subject (Article 6(1)(c) GDPR);
b) to establish or seek claims or to defense against claims – the legal basis for
processing is our legitimate interest (Article 6(1)(f) GDPR) involving protection of
our rights.
XI. Period of processing your personal data
Anshar will not use or store personal data for longer than is necessary to achieve the
above-mentioned purposes and will delete the collected personal data after the expiration
of the period necessary to achieve the purposes described herein or to fulfill contractual
obligations or to the extent permitted or required under applicable law. The specific
retention periods for personal data are indicated with each of the listed processing purposes
are as follows:
a) in case we process your data to perform the agreement (e.g. to provide you with
Website content, to enable you to use contact form, or to conduct e-mail
correspondence connected with the contract you concluded with us) – your data will
be processed for the duration of the agreement and after this period for a period no
longer than the period of the possible statute of limitations for claims;
b) in case we process your data on the basis of your consent – your data will be
processed not longer than necessary to realize purpose for which your consent is
granted, and no longer than until the moment you withdraw your consent;
c) in case we process your data to comply with our legal duties – your data will be
processed not longer than the term of these legal duties;
d) in case we process your data on the basis of our legitimate interest – your data will
be processed until our interest is realized (for example for the duration of
correspondence, for the time of subscription of Newsletter – no longer than until
you withdraw your consent to receive such a Newsletter), no longer than the statute
of limitations for claims, and no longer than until the moment you object to the
processing of your data for such purposes. In case we process your data to establish
or seek claims or to defend against claims – your data will be processed for the
duration of the proceedings and optionally the period of limitation of claims.
XII. Source of data
In general, we collect your data directly from you. However, there are situations in which
we receive your data directly from a third party. If you are an employee or representative
of our contractor, we may receive your identifying information (such as name, surname,
email address, position) from him.
Anshar does not knowingly solicit personal information from children or send them requests
for personal information. Although visitors of all ages may navigate through our Website
and use our Products, we do not intentionally collect personal information from persons
under the age of sixteen. We require parental consent to process the personal data of a
child under 16 years of age. Anshar encourage parents to instruct their children to never
give out personal information when online. If following a notification by a parent or
guardian, or discovery by other means, that a child under sixteen has improperly use our
Products by using false information, we will cancel the child’s account and delete the child’s
personal information from our records.
XIII. Your rights
In connection with the processing of your personal data, you have the right to:
a) object to the processing of your data, if the basis for processing is our legitimate
interest in accordance with art. 6 (1) (f) of the GDPR. In this case, we will no longer
process this personal data, unless we prove the existence of valid, overriding,
legitimate grounds for processing, or grounds for establishing, investigating or
defending claims;
b) withdraw consent to the processing of personal data (given by you) at any
time. This withdrawal does not affect the compliance of the processing which was
carried out on the basis of consent before its withdrawal;
Remember that you can also at any time withdraw your consent on marketing
content. In this case, we will no longer process your personal data for this purpose.
c) access your personal data;
d) require us to correct your data;
e) require us to delete your data to the extent provided for by law;
f) require us to limit the processing of your data to the extent provided for by law;
g) require us to transfer your data, if the processing is carried out by automated
means and if the data is processed in connection with a contract;
h) lodge a complaint with the local supervisory authority –in Poland President of the
Data Protection Authority (ul. Stawki 2, 00-193 Warszawa, more information:
https://uodo.gov.pl/en/484 )
XIV. Recipients of your data
Anshar Publishing does not and will not sell personal information about our customers. We
only disclose your data as authorized in this statement. We may share information with
the types of third parties described below and always ensure, when sharing information,
such third parties adhere to the same principles.
In respect of the data processing for the purposes specified in this Policy, the recipients of
your personal data may be the following:
a) our authorized personnel, as well as the authorized personnel of our subcontractors;
b) entities services to us, i.e operating our IT systems, website management, hosting,
advertising agencies, entities providing consulting, legal, debt collection, accounting
and auditing services, in particular:
i. provider of Mailchimp (emailing tool) – The Rocket Science Group LLC – if you
subscribe our Newsletter;
ii. provider of our email system – Microsoft Ireland Operations Limited – if we
correspond by e-mail;
iii. provider of the Discord messenger with the help of which we provide support
– Discord Netherlands BV. Discord Netherlands BV
iv. provider of Steam – with the help of which we provide support – Valve
Corporation
c) viewers of our social media posts about Stationary Events in which your image was
published;
d) other Anshar group companies and its personnel:
i. Anshar Studios S.A. to the extent that it provides services to us, in particular
IT and information security services;
ii. Anshar Studios S.A. to the extent that provides marketing services.
e) providers of social media indicated in point VIII;
f) providers of IT tools for creating surveys e.g. Alchemer LLC.
g) providers of Kickstarter and Backerkit platform.
We may also share non-personal information such as aggregated data with our partners
or publicly. For example, we may inform a games service about how their users have
utilized Anshar Publishing Products on their platform, or we may share the total sales of a
Anshar Publishing Product, or share overall game statistics with our audience.
We reserve the right to disclose selected information concerning you to the competent
authorities or to third parties who request such information on an appropriate legal basis
and in accordance with applicable law.
XV. Transfer outside EEA
The level of personal data protection outside the European Economic Area (EEA) differs
from that provided by European law. For this reason, we transfers personal data outside
the EEA only when necessary and with an adequate level of protection. Transfers outside
the EEA occur in particular:
a) in connection with use of the mailing tool – Mailchimp, transfers are made primarily
to the United States under standard contractual clauses approved by the European
Commission;
b) in connection with our support through Discord and Steam – transfers are made
primarily to the United States under standard contractual clauses approved by the
European Commission or other appropriate legal safeguards;
c) if our subcontractor is located outside the EEA – transfers are made most often
under standard contractual clauses approved by the European Commission or on
the basis of a decision of the European Commission finding a sufficient level of
protection of personal data in a given country.
In order to obtain a copy of the European Commission’s decision or standard contractual
clause, you can contact us using the data indicated in section II.
XVI. Safety of your data
Anshar is committed to protecting the security of your personal data. We use a variety of
security technologies and procedures to help protect your personal data from unauthorized
access, use or disclosure.
Anshar takes reasonable measures to help protect information about you from loss, theft,
misuse and unauthorized access, disclosure, alteration, and destruction.
The servers on which your personal information is stored are kept in a controlled
environment with limited access. While we take reasonable efforts to guard personal
information we knowingly collect directly from you, no security system is impenetrable.
XVII. Changes to this privacy policy
Anshar may modify or update this privacy policy when necessary to reflect customer
feedback and changes in our Products and Website; so, please review it periodically. When
we update this policy, we will revise the “Last Updated” date at the top of the statement.
