Privacy Policy
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use our Services and tells You about Your privacy rights and how the law protects You.
We use Your Personal Data to provide and improve our Services. By using the Services, You agree to the collection and use of information in accordance with this Privacy Policy.
1. Who we are (Data Controller)
Address: Aleje Jerozolimskie 155/U3, 02-326 Warsaw, Poland
NIP: 5223068517
REGON: 365072519
E-mail: [email protected]
Throughout this document “we”, “our” or “DR-Online” refers to the company above, which determines the purposes and means of processing your personal data in connection with our Services.
2. Interpretation and Definitions
Account means a unique account created for You to access our Services or parts of our Services.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Company (referred to as either “the Company”, “We”, “Us” or “Our”) refers to DR-Online sp. z o.o.
Country refers to: Poland
Device means any device that can access the Services such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Services refers to:
- The informational website for our mobile game Spaceship Builder
- The DR Net Tools mobile application
- All related services and functionalities
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing how the Services are used.
Usage Data refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.
3. How we collect personal data
| Source | Examples of data | Purpose & legal basis |
|---|---|---|
| Contact / support forms | Name, e-mail, message content | Respond to your enquiry (GDPR Art. 6 (1)(b)) |
| Server logs | IP, date/time, URL, browser headers | Security & site operation (Art. 6 (1)(f)) |
| Cookies & analytics | Pseudonymous IDs, device info, events | Traffic measurement & optimisation (Art. 6 (1)(a) consent or (f) legitimate interest) |
| Application usage | Usage data, location information | Provide app features (Art. 6 (1)(a) consent or (b) contract performance) |
4. Types of Data Collected
Personal Data
While using Our Services, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Usage Data
Usage Data
Usage Data is collected automatically when using the Services.
Usage Data may include information such as:
- Your Device’s Internet Protocol address (e.g. IP address)
- Browser type and version
- The pages of our Services that You visit
- The time and date of Your visit
- The time spent on those pages
- Unique device identifiers
- Other diagnostic data
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
- Information regarding your location
- Mobile device unique identifiers
- Mobile device operating system
- Type of mobile Internet browser
We use this information to provide features of Our Services, to improve and customize Our Services. You can enable or disable access to this information at any time, through Your Device settings.
5. Cookies
| Type | Example cookie / lifetime | Function |
|---|---|---|
| Essential (1st-party) | wordpress_logged_in_, cookieConsent (session – 1 yr) | Site operation, preference storage |
| Analytics (3rd-party) | *ga (2 yr), *ga_* (90 d), _gid (24 h) | Google Analytics 4 statistics |
| Tag-container | gtm_debug (session) | Loads GTM tags |
You may refuse non-essential cookies via the banner or your browser without losing access to any content.
6. Google Tag Manager & Google Analytics 4
GTM itself stores no personal data; it only loads measurement scripts. Google Analytics 4 collects usage data with IP-anonymisation in the EU. Data may be transferred to Google LLC in the USA under the EU–US Data Privacy Framework or Standard Contractual Clauses.
- Reject analytics cookies in the banner
- Install the GA opt-out browser add-on
7. Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Services, including to monitor the usage of our Services
- To manage Your Account as a user of the Services
- For the performance of a contract relating to products, items or services You have purchased
- To contact You by email, telephone, SMS, or other forms of electronic communication
- To provide You with news, special offers and general information about other goods and services
- To manage Your requests to Us
- For business transfers in case of merger, sale of assets or acquisition
- For other purposes such as data analysis, identifying usage trends, determining the effectiveness of promotional campaigns
8. Legal bases
- Contract / enquiry fulfilment – Art. 6 (1)(b) GDPR
- Legal obligations – Art. 6 (1)(c) GDPR
- Legitimate interests (security, analytics) – Art. 6 (1)(f) GDPR
- Marketing / analytics cookies – Art. 6 (1)(a) GDPR where consent is required
9. Sharing of Your Personal Data
We may share Your personal information in the following situations:
- With Service Providers to monitor and analyze the use of our Services
- For business transfers in connection with negotiations of any merger, sale or acquisition
- With Affiliates who will be required to honor this Privacy Policy
- With business partners to offer You certain products, services or promotions
- With other users when You share personal information in public areas
- With Your consent for any other purpose
10. Data retention
| Category | Period |
|---|---|
| Enquiry emails | 24 months after last reply |
| Server logs | 90 days (longer if investigating abuse) |
| Cookies | Up to lifetime shown in §5 or until deletion |
| GA4 reports | Aggregates 26 months; raw events as per GA settings (14 months) |
| Application data | As long as necessary for purposes set out in this Privacy Policy |
11. Recipients / international transfers
Hosting, e-mail and analytics providers process data under Art. 28 GDPR contracts.
Legal or regulatory bodies where required.
Transfers outside the EEA rely on adequacy decisions or SCCs with supplementary safeguards.
12. Your rights
You may at any time:
- Request access, rectification or erasure of your data
- Restrict or object to processing based on legitimate interests
- Receive a copy of data you provided (portability)
- Withdraw consent without affecting prior lawful processing
- Lodge a complaint with the Polish DPA (UODO)
Send requests to: [email protected]
We reply within one month.
13. Security of Your Personal Data
We use TLS encryption, access-control policies, regular software updates and network-level protections to guard data against loss, misuse or unauthorized access.
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
14. Children’s Privacy
Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.
If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
15. Links to Other Websites
Our Services may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
16. Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Services, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
17. Contact Us
If you have any questions about this Privacy Policy, You can contact us:
Postal address: Aleje Jerozolimskie 155/U3, 02-326 Warsaw, Poland