Privacy and Cookies Policy

As a general rule, you do not need to provide your Personal Data to use our services or contact us. We make every effort to process your data anonymously, in particular, as a rule, we do not process, for example, your name or payment card details. Occasionally, however, some information, depending on its content and use, may be linked to a specific player and thus be considered Personal Data.

For those exceptional cases when we happen to process your Personal Data, we have created this policy. It explains who we are, how we process your Personal Data, what cookies we use, what your rights are in this regard and how you can contact us if you need to.

The Privacy and Cookies Policy has been created for information purposes only, which means that it does not give rise to any legal obligations either for you or for the Controller (it is not a contract). Consequently, we reserve the right to amend this Privacy and Cookies Policy from time to time. The current version of this Privacy and Cookies Policy will be available under the following link: https://mechanistry.com/privacy.

We respect your privacy and strive in such cases to follow best practices in the area of processing your Personal Data – in particular in accordance with 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, also known as the General Data Protection Regulation (GDPR).

For information specific to other countries and regions where we operate, please see a relevant section under “VII. Local regulations” in this document.

I. Glossary – key terms.

Personal Data – all information relating to you that we process. For example: email address, player ID, etc.

Processing – all activities performed on Personal Data. For example: collecting, storing, updating, deleting data.

Website – www.mechanistry.com or any other website owned by the Controller, to which this Privacy Policy applies.

Game – Timberborn, the game created and developed by the Controller for entertainment purposes.

II. Who is the controller of your personal data?

The Controller of your personal data is Mechanistry sp. z o.o. with its registered office in Warsaw in the Republic of Poland (address: Rondo Daszyńskiego 2B, 00-843 Warsaw, Poland), registered in the Register of Entrepreneurs of the National Court Register kept by the District Court in Warsaw, 13th Commercial Division under KRS number: 0000630339, NIP (tax ID No): 5272775893, REGON (statistical ID No): 365026726, share capital: 500.000 PLN, email: hello@mechanistry.com.

III. What Personal Data do we collect, what is the purpose, duration and legal basis of the processing?

The scope of personal data we process depends on what information you provide e.g. when you use our Website, play the Game or when you contact us.

Provision of all data is voluntary, but if you decide not to provide us with some of them, we might not be able to answer your inquiry.

We process your personal data in line with applicable data privacy requirements including basing the processing on an appropriate legal basis. Such legal basis can be, for example, your consent, a legal obligation to which we are subject, or another legal basis as regulated by applicable laws.

Please be reminded, that in any case when Processing of Personal Data is based on your consent, you may revoke it at any time, without affecting the legality of Processing performed prior to such revocation. In case of Processing your Personal Data based on our legitimate interest, you may object to such Processing.

We process data for lawful periods. The Personal Data retention period may be extended as appropriate in the event of any claims (in particular by the periods of their expiration), and court proceedings or if the law will oblige us to process personal data for a longer period.

1. OUR WEBSITE

When you visit our Website you may grant us with a consent to use cookies technology, which allows e.g. for analyzing information about how you use our Website. We process this data in order to improve the quality of our website, match the content with the visitors’ interests, and constantly improve its performance. Some cookies also allow the marketing of services, both within our Website and as part of our partners' websites.

The legal basis for using the cookies and similar technologies is your consent, except when their use is necessary for the proper functioning of our website (providing you with electronic services), when the legal basis for such Processing will be legal provision, and respectively – our legitimate interest (Article 6(1) letter f of the GDPR).

Regardless, we can also process your Personal data in order to prevent and detect any security threats, fraud, or other malicious actions. In such a case, the legal basis for the Processing is our legitimate interest (Article 6(1) letter f of the GDPR).

Our Website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

For more information about our cookies policy please see a relevant section under “VIII. What are cookies and other similar technologies? How and for what purpose do we use them?” at the end of this document.

2. THE GAME

We may process your Personal Data as a result of your acquisition of our Game.

The purpose, as well as the legal basis for the processing, is, as a rule, proper performance of the agreement that we have concluded (Article 6(1) letter b of the GDPR) – enabling you to use the Game, providing support or advice. We may also process some of your Personal Data to fulfil legal obligations arising from applicable laws, for example, tax and accounting obligations – the legal basis for the processing is the need to comply with a legal obligation (Article 6(1) letter c of the GDPR).

Your data will be processed for no longer than the period required by tax or accounting regulations.

3. YOUR ACTIVITY IN THE GAME

You may grant us with a consent to use the technology that will enable us to collect information about how you use our Game. This type of information will be associated e.g. with a unique player ID, and therefore in some cases may be considered Personal Data.

The scope of information collected may include, but is not limited to, the following:

  • player ID;
  • information about the hardware / software you use, such as the type of processor, graphics card, operating system, etc.;
  • the in-game actions you perform, for example: what difficulty level you play on, what are your favourite scenarios, etc.;
  • gameplay times: how often do you play and for how long, etc.;
  • information about game errors (crash reports).

We will collect and analyze this data in order to maintain the highest quality of the Game and ensure high level gaming experience, in particular we will process the data for the following purposes:

  • deciding on the direction of the Game's development;
  • optimization of the Game;
  • improving the tutorial;
  • increasing the attractiveness of the Game;
  • developing the functionality of the Game;
  • testing the effectiveness of the Game.

The data we collect in no way will be used to influence your single gameplay. In particular, as part of our operations, we do not profile you or make automated decisions regarding you as a player. Based on the data, we will only make directional decisions on the development regarding the entire Game.

The legal basis for our activity, apart from your freely given consent, is our legally justified interests (Art. 6(1) letter f of the GDPR), that is the use of legal acquired data for above-mentioned purposes.

Your data will be processed for no longer than 24 months. You may revoke your consent at any time using the in-game settings menu. Your withdrawal will not affect the lawfulness of the processing of your data carried out prior to such withdrawal.

For the purpose of understanding Game performance and your behavior in our Game we will use the Unity Analytics tool, provided by Unity Technologies SF, which is also a recipient of your personal data (processor). In the limited circumstances Unity Technologies SF may be an independent controller of Personal Data. The protection and use of Personal Data by Unity Technologies SF is described in its privacy policies, for example here: https://unity.com/legal/.

4. SOCIAL MEDIA PROFILE / SERVER (E.G. DISCORD)

Your Personal Data, including those you provide when visiting our social media profiles / servers (such as comments, internet identifiers), are or may be processed for the following purposes:

  • facilitating your activity on the profile, effectively managing our profile by providing information about our initiatives and other activities, and promoting the Game, various events and services, including those of our partners – legal basis: Article 6(1) letter f of the GDPR, i.e., the legitimate interests pursued by the Data Controller or a third party, such as promoting the brand and improving the quality of services provided;
  • marketing activities of the Data Controller or our partners, such as presenting advertisements and offers. Legal basis for the aforementioned activities: Article 6(1) letter f of the GDPR, i.e., the legitimate interests of the Data Controller or a third party (own marketing of the Data Controller or our partners);

Your Personal Data will be processed for the period necessary to achieve the above purposes or until you effectively object, unless a longer period results from their storage in case of potential claims, for the limitation period specified by legal provisions. In each case, the longer storage period of Personal Data will apply.

5. CONTACT WITH US

When you contact us, for example, via email, social media, etc., your Personal Data is processed to answer your enquiry, to improve our communication, to enhance customer service and for marketing purposes.

The purpose of the processing and the legal basis for the processing depends on the context of the communication. If you contact us only to obtain general information, e.g. about the Game, we will process your Personal Data based on our legitimate interest (arising from the purposes mentioned above; Article 6(1) letter f of the GDPR). However, in the event that your enquiry leads to the conclusion of a service agreement, the relevant legal basis for the processing will be Article 6(1) letter b of the GDPR – taking steps at the request of the data subject prior to entering into a contract. If a contract is already in place and you contact us about its performance, the basis for our actions is Article 6(1) letter b of the GDPR – necessity for the performance of a contract.

If your Personal Data has only been collected in connection with our current communications, we may process it, depending on the category of individual information, for a period ranging from a few days to several months (more specific enquiries and conversations that may be relevant to our contact in the future).

Your Personal Data processed on the basis of our legitimate interest may be stored until you object to its processing, except where, despite your objection, we conclude that there are compelling legitimate grounds for the processing overriding your interests, rights and freedoms, or grounds for establishing, exercising or defending claims.

The protection and use of Personal Data by social media sites that you might use when contacting us is described in their privacy policies. For example, information on the processing of Personal Data by Facebook can be found at: https://www.facebook.com/policy.php.

6. NEWSLETTER

Remember that you can withdraw your consent to receive marketing information at any time.

We will process your personal data for marketing purposes such as providing you with interesting information about the Controller or the Game, including any future competitions, events etc. The legal basis of processing your e-mail address is our legitimate interest (Article 6 (1) letter f of the GDPR).

Your personal data will be processed until you resign from our newsletter.

7. CONTESTS

Personal data received from contestants are processed in order to conduct and adjudicate a contest and perform the obligations arising from the contest.

The purpose of Processing the data and the legal basis as well, is proper implementation of the agreement (Art. 6 (1) letter b of the GDPR) concluded with you by way off an acceptance of the terms and conditions of our contest and compliance with a legal obligation to which we are subject to e.g. tax and accounting obligations (Art. 6(1) letter c of GDPR).

Your data will be processed for the period necessary for proper execution and settlement of the contest.

We may also be obligated – if there is a legal basis for that – to disclose certain information to public authorities for tax reasons.

8. MARKETING

Your Personal Data provided by you, but also other data collected in connection with your activity on our Website, are or may be processed for the purposes connected with marketing, analytical and statistical activities of the Controller or its partners or other so-called third parties with whom we cooperate.

The legal basis for processing your personal data in accordance with this purpose will be our legitimate interest (Art. 6(1) letter f of GDPR) – maintaining relations and building a positive image of Mechanistry and marketing of the Game and our services.

9. ANALYTICS, CLAIMS, SECURITY THREATS

Additionally, with regard to the Processing of your Personal Data:

  • for internal record keeping, administrative purposes, analytics and statistical purposes, the legal basis for Processing of your Personal Data will be our legitimate interest (Art. 6(1) letter f of GDPR);
  • to defend against potential claims, as well as for the purpose of potential directing claims, in order to prevent and detect any security threats, fraud, or other malicious actions, the legal basis for Processing of your Personal Data will be our legitimate interest (Art. 6(1) letter f of the GDPR).

IV. Who has access to your Personal Data?

Access to your personal data will be given exclusively to our appropriately authorized employees or associates, our vendors, partners, consultants or auditors and only to the extent necessary to perform their responsibilities.

Only entities that support us under appropriate agreements, such as entities that provide hosting/IT services or tools to enable our communications, marketing campaigns, our advisors, including legal counsel, entities that provide online payment services, will receive access to your Personal Data.

All these entities will have access only to the information necessary for their activities.

Some of those providing solutions to us may be established outside the European Economic Area (EEA). Whenever we transfer data outside the EEA, we apply the required security measures, including standard data-protection clauses adopted under a decision of the European Commission, with appropriate safeguards. You may contact us to receive a copy of the safeguards used by us concerning the personal data transfer to countries outside EEA.

For example, the recipients of your personal data are:

  • Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg – providing the Controller with tools for storage and internal management of data, and for sharing them as well as collecting Game crash reports;
  • Webflow, Inc., 398 11th Street, 2nd Floor San Francisco, CA 94103, United States of America – providing the Controller with website hosting tools;
  • The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA – providing the Controller with assistance in managing the Controller’s newsletter and electronic communications by way of providing appropriate tools.

We may also be required – if there is a legal basis to do so – to provide certain information to public authorities, for purposes related to proceedings they are conducting.

In the event that you are redirected to websites of entities other than the Controller, we do not provide such entities with your Personal Data. To the extent that related websites visited by you are not our websites, we are not responsible for the processing of Personal Data related to the use of these websites. In order to understand the principles of data processing on these websites, you should refer to the privacy policies made available on these websites.

V. Your rights related to the processing of your personal data

In order to ensure the efficient exercise of your rights, please send all requests to the email address set out in the glossary, write “Privacy Request” in the subject line and specify which right you wish to exercise in the body of the email. The instructions in the preceding sentence are only a recommendation and not a requirement. Making a request in another way will not lead to the loss of the rights listed below.

At any time you have the right to:

  • access your Personal Data (including, for example, to obtain information which Personal Data are processed or a copy thereof);
  • request rectification and restriction of processing (e.g. where the Personal Data is incorrect) or erasure of Personal Data (e.g. where it has been processed unlawfully);
  • portability of the Personal Data you have provided to the Controller and which is processed by automated means and the processing is based on consent or on contract, for example, to another controller;
  • withdraw any consent given to the Controller at any time, and the withdrawal of consent will not affect the processing carried out by the Controller lawfully prior to its withdrawal;
  • object to the processing of Personal Data carried out for the purpose of pursuing legitimate interests of the Controller or of a third party (where there are no other valid legitimate grounds for processing which override your interests). Where Personal Data is processed for direct marketing purposes, you will have the right to object at any time to the processing of your Personal Data for such marketing, including profiling, to the extent that the processing is related to such direct marketing, in which case the Personal Data must no longer be processed for such purposes.
  • lodge a complaint to a supervisory authority.

If you would like to file a complaint to the data protection authority, you can find list of local authorities responsible for data protection across the EU and their contact details at: https://edpb.europa.eu/about-edpb/board/members_en.

The relevant public authority in the UK is the Information Commissioner’s Office https://ico.org.uk/global/contact-us/. The relevant public authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC) https://www.edoeb.admin.ch/edoeb/en/home.html.

Of course, if you wish to report comments on the way we operate, we encourage you to contact us first.

VI. How do we secure your data?

The Controller, taking into account the state of technical knowledge, the cost of implementation and the nature, scope, context and purposes of processing, as well as the risk of violation of the rights or freedoms of individuals with different probability of occurrence and severity of the threat, shall apply appropriate technical and organizational measures to ensure the protection of the processed Personal Data appropriate to the threats and categories of protected data, and in particular shall protect the data from being made available to unauthorized persons, from being taken by an unauthorized person, from being processed in violation of applicable regulations, and from being altered, lost, damaged or destroyed. Sharing information externally about the technical and organizational measures in place to ensure the protection of processing may undermine their effectiveness, thereby jeopardizing the proper protection of Personal Data.

VII. Local regulations

In case of any discrepancies between this privacy policy and Section VII (Local regulations), the latter shall prevail.

The provisions of this policy do not exclude or limit any of your rights under mandatory provisions of law, and we will interpret any doubt in your favor. In the event of any unintentional inconsistency between the provisions of this policy and the aforementioned laws, those laws shall prevail and shall be applied by us.

1. ADDITIONAL INFORMATION FOR RESIDENTS OF UK

When GDPR is referred to in this policy, it should also be understood as UK GDPR.

2. ADDITIONAL INFORMATION FOR RESIDENTS OF CHINA

When processing Personal Data we take into account the principles arising from the Personal Information Protection Law of the People’s Republic of China.

By using our services, you agree to this Privacy Policy and understand that we may transfer your data outside of the People’s Republic of China.

We will engage our activities with your consent or where it is necessary to fulfill our agreement.

If you would like to file a complaint to the data protection authority, please find more details here: https://www.dspdp.gov.mo/zh_tw/index.html.

3. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA

When processing Personal Data we take into account the principles arising from the California Consumer Privacy Act.

If you are a California resident, you have rights in relation to your Personal Data:

  • Right to Know - you may have the right to obtain a copy, or a list of categories of the Personal Data that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your Personal Data;
  • Right to Opt Out of Sale/Share - you have the right to opt-out of the sale of your Personal Data in exchange for monetary or other valuable consideration, including sharing of your Personal Data to third parties for behavioral advertising purposes. We generally do not sell your Personal Data for profit, but like many websites, we use cookies and similar technology. Please note that you may still receive generalized ads after opting out of targeted advertising
  • Right Against Discrimination - you have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
  • Direct Marketing - if you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes.

Please find more details about Personal Data protection here https://oag.ca.gov/privacy.

VIII. What are cookies and other similar technologies? How and for what purpose do we use them?

Cookies are small data files that are placed on your device when you visit the Website. We may use cookies and other technology to recognise you as a returning visitor of our Website, to improve the quality of our service and to collect statistical data, and for marketing purposes. We also process them to analyse the popularity and effectiveness of our offers.

The information collected in cookies will not necessarily constitute Personal Data. However, some information, depending on its content and use, may be linked to a specific person and thus be considered Personal Data.

Of course, you can change the way cookies are used, including blocking them completely or deleting them via your browser settings. However, you should remember that this type of action may prevent or significantly hinder the proper functioning of our Website, for example, by significantly slowing it down, so we recommend that you do not disable cookies in your browser.

Most browsers also provide functions for viewing and deleting cookies. Please remember that disabling or blocking certain cookies may prevent or significantly hinder the proper functioning of our website, for example by slowing it down.

Browser producers provide help pages on how to manage cookies in their products. You can find more information below.

For other browsers, please refer to the documentation provided by the browser producer.

If you wish to manage your cookie consents on our Website, we provide a tool for this purpose. Its interface shows all types of cookies with their description and also allows you to decide which types of cookies you accept. You can easily change these settings at any time using the dedicated functionality available under the “Manage cookies” or similar button available on our Website. It is displayed at the bottom of the page at all times when you use our website.

We provide you with information that explains precisely which cookies we use and for what purposes.

We use two types of cookies: session cookies, which remain stored on your computer or mobile device until you close the Website, and permanent cookies, which remain on your device for the time specified in the parameters of the cookies or until they are manually deleted in your software.

Depending on the circumstances, we may use the following types of cookies, without limitation:

  • Technical – necessary for the proper functioning of the Website and the functionalities available within the Website; adapting and optimising the Website to your needs; these cookies are not used to track visitors of the Website;
  • Analytical/performance – used to analyse your behaviour on the Website, for statistical and analytical purposes; they help us to achieve our legitimate aims of improving the way our site works; for example, by ensuring that you can easily find what you are looking for;
  • Marketing – used to analyse your behaviour; they provide information that may identify you, including for marketing purposes within third party websites; we will use this information, taking into account your choices and preferences, to make our site more relevant to your interests. We may also share this information with third parties for this purpose.

To see a detailed description of the cookies we use, click the relevant box in the cookies bar.

We may work with other companies on their marketing (advertising) activities. For the purposes of this collaboration, your browser or other software installed on your device may also place cookies from entities conducting such marketing activities and those entities may become the controllers of your Personal Data (these are called “third party cookies”). Cookies sent by these entities are intended to ensure that you are presented with only those advertisements that match your individual interests and needs. We believe that displaying personalised advertising may be more attractive to you than advertising that is unrelated to your needs. This would not be possible without these files, as it is the companies working with us that provide advertising content for you.

We may use the following entities or services of entities that may use cookies on the Website:

The aforementioned entities may become controllers of your Personal Data in connection with the use of their cookies on the Website. For more information on the cookies of these entities, please refer to their privacy policies.

Last update of this Privacy and Cookies Policy: April 5, 2024

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