In order to preserve the right to privacy of the users of the Kinguin.net platform (hereinafter referred to as “Platform”) and to meet the requirements of the law, Kinguin Digital Limited, 5/F Chung Nam Building, 1 Lockhart Road, Wan Chai, Hong Kong (hereinafter referred to as “Kinguin”) publishes a document in which it explains and informs the manner in which Personal data provided by users of the Kinguin.net platform (hereinafter referred to as „Users”) and unregistered Kinguin.net users („Guests”) is collected, processed and secured. Before the start of the use the services or making registration to be the User, the Guest and the User should familiarize with the content of this Privacy Policy.

Kinguin Digital Limited, a Hong Kong company with a company number 1915649, 5/F Chung Nam Building, 1 Lockhart Road, Wan Chai, Hong Kong (hereinafter referred to as „the Controller”) regarding data provided by the User/Guest during use of Kinguin services. Kinguin processes Personal Data in accordance with applicable laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th 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) (hereinafter referred to as „GDPR”).

Users´ data are processed in particular for the following purposes:

• providing the services to the User and performing the contract and its settlement,
• providing content and products to Users, including content/products tailored to their interests,
• measuring and improving content and services,
• informing about the services of Kinguin and content and products of other companies cooperating with Kinguin,
• sending a free newsletter with information on Kinguin, provided that the User has previously agreed to receive marketing correspondence from Kinguin,
• ensuring the security of information processing in Kinguin,
• management of ICT systems,
• claiming.

To the extent to which Users' Personal data are processed in order to improve the content and services of Kinguin, provide information on other Kinguin services, as well as provide personalized marketing content on the Platform, carry out research and analysis regarding products, services, Kinguin and third parties advertising, the legal basis for the processing of Users' Personal data is the legitimate interest of Kinguin. It is in the interest of Kinguin to provide, improve its services, ensure their best quality and inform Users about them.

Guest's data are processed in particular for the following purposes:

• providing the services to the Guest and performing the contract and its settlement,
• ensuring the security of information processing in Kinguin,
• management of ICT systems,
• claiming.

The purpose, legal backgrounds and period for processing your data for specific purposes are as follows:

• Processing of Personal data in order to perform a contraction the Kinguin - User/Guest line (these agreements are usually regulations that the User/Guest accepts before using a given service), including providing services to Users/Guest, matching the services to the needs of Users, analysing and improving the services and ensuring the security of the services (hereinafter 'performance of the services') - the legal background is Art. 6 pts 1 b) GDPR - necessity to perform the contract to which the User/Guest is a party. Personal Data will be processed during the performance of the relevant contract between the User/Guest and Kinguin, with the provision that sometimes, these data can be processed also after the expiration of the contract, but only if it is allowed or required under applicable law e.g. processing for statistical, billing or claims purposes.
• Processing of Personal data in order to carry out statistical measurements (hereinafter 'statistics'), marketing (including presenting data for marketing purposes) of the administrator´s products and services (hereinafter also: 'own marketing') - the legal background is Art. 6 pts 1 f) GDPR - the legitimate interest of the Controller. Personal Data will be processed until the application of effective opposition.
• Processing of Personal data for the marketing purposes (analysing data for marketing purposes) relating to the products and services of third parties (also referred to as 'third parties marketing') - the legal background is Art. 6 pts 1 a) GDPR - voluntary consent. Personal Data will be processed until withdrawal of consent.
• Processing of Personal data in order to send the newsletter from Kinguin through User´s account on the Platform. Newsletter may contain content tailored to User's interests, based on User's activity and viewed content. The legal background in case of newsletter is Art. 6 par. 1 a) GDPR - voluntary consent. Personal Data will be processed until withdrawal of consent.
• Processing of Personal data in order to comply with applicable laws (anti-money laundering obligations, protecting Kinguin rights. The legal background is Art. 6 pts 1 f) GDPR - the legitimate interest of the Controller. Personal Data will be processed by period - until the termination of the relevant contract between the User/Guest and Kinguin, with the proviso that sometimes, these data can be processed also after the expiration of this contract, but only if it is allowed or required under applicable law.

Providing Personal data is voluntary, but failure to provide data marked as necessary to render services to the User/Guest will make impossible to provide them.

Kinguin, in principle, does not provide User´s/Guest´s Personal data to third parties, except for situations in which Kinguin has a legal basis to do so, and at the request of entitled entities, or when it is necessary to perform services offered at the Platform. User's/Guest's Personal data may be transferred to entities processing Personal data on behalf of the Controller, among others, administrative, tools, payment, back office, legal service providers, as well as IT service providers, marketing, genius, etc. — nonetheless, such entities process data on the basis of a contract with the administrator and only in accordance with the administrator´s instructions. The User´s/Guest's Personal data may also be transferred to entities authorized to obtain them on the basis of the applicable law, e.g. law enforcement authorities in the event of a request being made by the authority on the appropriate legal basis (e.g. for the purpose of conducting a criminal proceeding). User´s/Guest´s Personal data may be transferred to recipients from third countries, ie. from countries outside the European Economic Area, eg. if it is necessary for the provision of services to the User/Guest or if it will be conditioned by a different, important legal basis.

Kinguin uses the YouTube API Services in order to provide functionality such as featuring thumbnails for YouTube videos. To learn more about how Google manages and protects your information, please see Google's Privacy Policy https://policies.google.com/privacy.

The User/Guest has the following rights in relation to the processing of his Personal data by Kinguin:

• The right of access to Personal data: At the user´s/Guest´s request, Kinguin will inform what Personal data of the User/Guest Kinguin processes and provide User/Guest with a copy of such data. In any case, the registered User has access to Personal data provided to Kinguin through the User ´s account on the Platform.
• The right to correct Personal data: In case the User´s/Guest´s Personal data is inaccurate or incomplete, the User/Guest may demand from Kinguin on correcting or supplementing them. In any case, the registered User has the option of correcting User´s Personal data through the User ´s account on the Platform.
• The right to erase Personal data (in certain situations): In certain situations, the User/Guest may claim Kinguin to remove Personal data processed by Kinguin (e.g. when data is no longer required to provide services to User).
• The right to limit the processing of the Personal data: The User/Guest may demand in certain situations that Kinguin temporarily suspend processing of his Personal data. For example, a User/Guest may request to restrict the processing of his Personal data when he objects to the processing or when he questions the correctness of the data. Despite the restriction of processing, Kinguin will still be entitled to hold Personal Data. Saved Personal data will be limited to storing purchase data.
• The right to request the transfer of Personal data: In certain situations (eg. in relation to data processed on the basis of consent), the User/Guest also has the right to receive Personal Data processed by Kinguin in a structured, commonly used machine-readable format to transfer this data to another Controller.
• The right to object to the processing of Personal Data: The User/Guest may demand that Kinguin cease processing his Personal data. – Kinguin processes User ´s/Guest's Personal data based on the legitimate interest of his or her third party, except in situations where these interests are superior to the interests, rights and freedoms of the User/Guest. – User´s data are processed for direct marketing purposes. – Objecting includes automated decision making towards the User, including profiling.
• The right to file a complaint with the supervisory body dealing with the protection of personal data: The User/Guest who is not satisfied with the way Kinguin processes Users/Guests Personal Data shall contact Kinguin at gdpr@kinguin.net and if the answer will not meet User´s/Guest's expectations, the User/Guest can file a complaint to the appropriate Personal Data Protection Authority in the User´s/Guest's country of residence.
• The right to withdraw consent in cases in which Personal data are processed on this basis: The withdrawal of consent does not affect the lawfulness of the processing of the Personal data in the period from the date of consent to the processing Personal data until the date of withdrawal of the consent.

In order to exercise the above rights, please contact the Controller – gdpr@kinguin.net.

Kinguin stores Users´/Guests Personal data only for the time that is necessary to achieve the purposes for which the data was collected. After this time, the data is deleted or anonymized in such a way that it is not possible to establish the identity of the User/Guest. Personal data may be stored for longer if such an obligation arises from the provisions of law or if it is necessary for Kinguin to defend or seek claims against Users/Guests.

The Platform use mechanisms of automatic data storage-mechanism of the type: 'cookies'. They are used to better adapt the Platform to the needs of Users/Guests. For purposes of this policy, mechanisms for automatic data storage will be referred to as „Cookies”. „Cookies” are files saved on the User's/Guest's end device, used to identify the User's/Guest's browser while using the Platform. They are used to provide the Controller statistical information about Users/Guests `traffic, Users´/Guest's activity and the manner of using the Platform and its services. They allow Kinguin to adjust the content and services to the User's/Guest's preferences. Most 'cookie' files are so-called session cookies that are automatically deleted from the hard disk after the session ends (that is, after logging out or closing the browser window). Some of the 'cookies' allow the identification of the end device of the User/Guest when visiting the Platform again - they are not deleted automatically, they are saved on the end device. In the case of mobile devices, as in the case of stationary devices, the mechanism of accepting 'cookies' has been used, which allows memorizing information related to a given User/Guest. Kinguin informs that third parties, including those not affiliated with Kinguin, in order to display advertisements on the Platform, may place their 'cookie' files in the browsers of the Users/Guests. The Platform also use a third party service, thanks to which Kinguin obtains anonymised reports on the use of the Platform and the effectiveness of marketing campaigns. A User/Guest who does not agree to such a way to monitor his behaviour should express his opposition on the website of such an entity.

We use cookies and other similar technologies for the purposes of:

• providing services;
• adapting the content of the Platform to the User´s/Guest´s preferences and optimizing the use of the Platform; e.g. cookies allow in particular to identify the User´s/Guest´s device and properly display the Platform adapted to its individual needs;
• creating statistics that help to understand how Users/Guests use the Platform, which allows improving its structure and content;
• maintaining the User´s session (after logging in), thanks to which the User does not have to re-enter their login and password on each subpage of the Platform;
• advertising presentation, including in a way that takes into account the interests of the User or his place of residence (individualising the advertising message) and with the guarantee of excluding the possibility of repeatedly presenting the same advertisement to the User;
• surveys - in particular to avoid multiple presentations of the same questionnaire to the same Recipient and to present surveys in a way that takes into account the interests of the recipients.