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NEMESIS: LOCKDOWN EULA
We care deeply about our customers’ privacy, security, and online safety, all of which are a significant
part of becoming trustworthy and reliable business partner. This Privacy Policy („Policy”) is designed
to inform you about how we collect, use, and share your personal data, your rights and choices
regarding the information you provide to us – especially in accordance with 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, also
known as General Data Protection Regulation (“GDPR”), that entered into force on 25th May, 2018.
Contents:
1. Basic definitions.
2. What personal data do we collect and process, what is the purpose of processing and what is the
legal basis?
3. How long do we process your personal data for?
4. Who has access to your personal data?
5. What are your rights regarding your personal data?
1. BASIC DEFINITIONS
Personal data – any information relating to you, that allows your identification i.e.: name, surname,
e-mail address, phone number, IP address etc.;
Customer, you – an adult individual with full legal capacity, a legal entity or organizational unit without
legal personality but with capacity to perform legal acts;
Controller – Realms Distribution Sp. z o.o. (limited liability company) with its registered office in
Wrocław (50-127) at the following address: ul. św. Mikołaja 58, entered into the registry of
entrepreneurs of the Polish National Court Register kept by the District Court for Wrocław-Fabryczna,
VIth Commercial Division under KRS number 0000637257, holder of Business entity statistical
number (REGON): 365403324, Polish taxpayer’s identification number (NIP): 8992798122, holder of
share capital in the amount of 5,000,00 PLN („Realms Distribution”).
Services – all services provided to the Customer by the Controller.
2. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, WHAT IS THE PURPOSE OF
PROCESSING AND WHAT IS THE LEGAL BASIS?
Currently, the only data based on which Realms Distribution can link you as a player with your identity
as a natural person, is your Steam ID or - as long as your Steam profile is public - other information
shared by you on your public Steam profile. We process such data for the purpose of enabling your
gameplay, and such processing is necessary for the performance of a contract between you and us
(art. 6.1(b) of the GDPR). Providing us with such data is not your legal obligation, but it is necessary
for you to make use of our Services and play the Nemesis: Lockdown Digital game.
Any other data collected during the game by Realms Distribution is not Personal Data within the
meaning of the GDPR. Realms Distribution collects gameplay data in order to provide the necessary
information for the game development. Gameplay data is linked to a unique Player ID, to which
Realms Distribution does not collect and assign data of a natural person. Such data may typically
include gameplay-related information such as choices made in the game and reaction time, or
hardware-related information such as type of graphics card, type of CPU, number of FPS, and RAM
usage.
Please also be aware that in case you contact us or create a claim, we will collect and store your
Personal Data such as name, surname, e-mail address, phone number, etc. in accordance with our
legitimate interest for the period specified in point 3 (based on the art. 6.1.(f) of the GDPR).
We may also process your Personal Data if it is necessary for us to comply with our legal obligation
(based on the art. 6.1.(c) of the GDPR) or if you give us your consent to the processing for one or
more purposes (based on the art 6.1(a) of the GDPR).
3. HOW LONG DO WE PROCESS YOUR PERSONAL DATA FOR?
We store personal data not longer than the time necessary to achieve the purposes, for which they
are processed.
Your Steam ID is being processed for as long as you have an active account in the game.
If we process your personal data to determine or assert any claims or to defend against above
mentioned Customer’s claims (the legal ground for this action is our legitimate interest, we store the
personal data until the laps of the limitation period for those claims, which arise from the generally
applicable provisions of law.
If we process your personal data to comply with our legal obligation, we store the personal data for
a period of performing such obligation.
If we process your personal data on the basis of your consent, such data is being processed until the
withdrawal of your consent or by the time the purpose, for which it was collected, ceases to exist.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA?
If we ever collect your Personal Data you can rest assured that the access to your personal data will
be granted only to:
● authorized employees and co-workers, who are obliged to keep them secret and not to use
them for purposes other than those for which we have collected them,
● entities that support us in service providing, based on appropriate contracts e.g. legal,
consulting, telecommunication service providers.
All these entities will have access only to necessary information.
Please also be aware that while you are playing the game in multiplayer mode, other players will be
able to see your Steam ID or - as long as your Steam profile is public - other information shared by
you on your public Steam profile.
Sometimes, the entities providing us with solutions are registered outside the European Economic
Area (EEA). In this case, if your personal data is processed outside the EEA, we will provide the
appropriate legal mechanisms for their security, including standard data protection clauses adopted
under the decision of the European Commission, and - if necessary - we conclude data processing
agreements that meet the requirements of the GDPR. You have the right to access the list of such
recipients and a copy of the security measures we use. If we do not provide adequate security
measures, we will inform you about it and ask for your consent to transfer such data. Without
adequate protection or possible consent, we will not undertake the transfer of your Personal Data
outside the EEA.
We may also be required to provide specific information relating to you, to public authorities for the
purposes of proceedings conducted by them. In this case, the information is provided only if there is a
proper legal ground.
5. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
Every Customer has the following rights:
1. Right of access. In any time, you can obtain from us confirmation as to whether or not your
personal data are being processed, access to the personal data and the following information:
● the purposes of the processing;
● the categories of personal data concerned;
● who are the recipients;
● where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period;
● where the personal data are not collected from the data subject, any available information as
to their source;
● the existence of automated decision-making, including profiling, and, at least in those cases,
meaningful information about the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject.
2. Right to rectification. If you feel that the information relating to you is incorrect or incomplete, you
have the right to request the rectification of the data.
3. Right to withdraw the consent. you can withdraw your consent at any time, without affecting the
legality of the processing, which was performing prior to this withdrawal.
4. Right to erasure (‘right to be forgotten’). The GDPR gives you the right to obtain from us the
erasure of all your personal data. We are obligated to make your request, only if one of the following
grounds applies:
● your personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed;
● you withdrew consent on which the processing is based and where there is no other legal
ground for the processing;
● you object to the processing and there are no overriding legitimate grounds for the
processing;
● you object to the processing for direct marketing purposes;
● the personal data have been unlawfully processed;
● the personal data have to be erased for compliance with a legal obligation in European Union
or Member State law to which the controller is subject;
● the personal data have been collected in relation to the offer of information society services
referred to in Article 8(1) GDPR.
5. Right to restriction of processing. You can also obtain the restriction of processing, where one of
the following applies:
● you contest the accuracy of the personal data – for a period enabling the controller to verify
the accuracy of the personal data;
● the processing is unlawful but you oppose the erasure of your personal data and you request
the restriction of their use instead;
● we no longer need your personal data for the purposes of the processing, but they are
required by you for the establishment, exercise or defence of legal claims;
● you have objected to processing – only until the dispute is resolved.
6. Right to data portability. You have right to receive your personal data in a structured, commonly
used and computer-readable format and have the right to transmit those data to another controller,
when:
● the processing is based on your consent or on a contract, and
● the processing is carried out by automated means.
7. Right to object. According to GDPR you have right to object:
● to processing of personal data, when it is necessary for the performance of a task carried out
in the public interest or in the exercise of official authority vested in Controller – on grounds
relating to your particular situation;
● to processing of personal data, when it is necessary for the purposes of the legitimate
interests pursued by Controller or by a third party, except where such interests are overridden
by the interests or your fundamental rights and freedoms which require protection of personal
data, in particular where the data subject is a child, including profiling – on grounds relating to
your particular situation;
● at any time – to processing of personal data for direct marketing purposes, which includes
profiling to the extent that it is related to such direct marketing;
● to processing of personal data for scientific or historical research purposes or statistical
purposes – on grounds relating to your particular situation.
If, in spite of the Customer's objection, we consider that there are important, legally valid grounds for
processing personal data, which override the Customer's interests, rights and freedoms, we can
continue processing the Costumer’s personal data.
If you disagree with above mentioned Controller’s situation assessment, you have the right to lodge a
complaint with a supervisory authority (for more information, see point VII below).
8. Right to lodge a complaint with a supervisory authority. Due to our actions as a Controller, you
have the right to lodge a complaint with a supervisory authority, in particular in the Member State of
your habitual residence, place of work or place of the alleged infringement.
If you want to lodge a complaint in Poland, since 25th May 2018 the function of the supervisory
authority is held by the President of the Data Protection Office / Prezes Urzędu Ochrony Danych
Osobowych (PUODO). A detailed description of the procedure for lodging a complaint to PUODO is
available on the website maintained by PUODO which you can access by clicking the following link:
https://uodo.gov.pl/.
We care deeply about our customers’ privacy, security, and online safety, all of which are a significant
part of becoming trustworthy and reliable business partner. This Privacy Policy („Policy”) is designed
to inform you about how we collect, use, and share your personal data, your rights and choices
regarding the information you provide to us – especially in accordance with 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, also
known as General Data Protection Regulation (“GDPR”), that entered into force on 25th May, 2018.
Contents:
1. Basic definitions.
2. What personal data do we collect and process, what is the purpose of processing and what is the
legal basis?
3. How long do we process your personal data for?
4. Who has access to your personal data?
5. What are your rights regarding your personal data?
1. BASIC DEFINITIONS
Personal data – any information relating to you, that allows your identification i.e.: name, surname,
e-mail address, phone number, IP address etc.;
Customer, you – an adult individual with full legal capacity, a legal entity or organizational unit without
legal personality but with capacity to perform legal acts;
Controller – Realms Distribution Sp. z o.o. (limited liability company) with its registered office in
Wrocław (50-127) at the following address: ul. św. Mikołaja 58, entered into the registry of
entrepreneurs of the Polish National Court Register kept by the District Court for Wrocław-Fabryczna,
VIth Commercial Division under KRS number 0000637257, holder of Business entity statistical
number (REGON): 365403324, Polish taxpayer’s identification number (NIP): 8992798122, holder of
share capital in the amount of 5,000,00 PLN („Realms Distribution”).
Services – all services provided to the Customer by the Controller.
2. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, WHAT IS THE PURPOSE OF
PROCESSING AND WHAT IS THE LEGAL BASIS?
Currently, the only data based on which Realms Distribution can link you as a player with your identity
as a natural person, is your Steam ID or - as long as your Steam profile is public - other information
shared by you on your public Steam profile. We process such data for the purpose of enabling your
gameplay, and such processing is necessary for the performance of a contract between you and us
(art. 6.1(b) of the GDPR). Providing us with such data is not your legal obligation, but it is necessary
for you to make use of our Services and play the Nemesis: Lockdown Digital game.
Any other data collected during the game by Realms Distribution is not Personal Data within the
meaning of the GDPR. Realms Distribution collects gameplay data in order to provide the necessary
information for the game development. Gameplay data is linked to a unique Player ID, to which
Realms Distribution does not collect and assign data of a natural person. Such data may typically
include gameplay-related information such as choices made in the game and reaction time, or
hardware-related information such as type of graphics card, type of CPU, number of FPS, and RAM
usage.
Please also be aware that in case you contact us or create a claim, we will collect and store your
Personal Data such as name, surname, e-mail address, phone number, etc. in accordance with our
legitimate interest for the period specified in point 3 (based on the art. 6.1.(f) of the GDPR).
We may also process your Personal Data if it is necessary for us to comply with our legal obligation
(based on the art. 6.1.(c) of the GDPR) or if you give us your consent to the processing for one or
more purposes (based on the art 6.1(a) of the GDPR).
3. HOW LONG DO WE PROCESS YOUR PERSONAL DATA FOR?
We store personal data not longer than the time necessary to achieve the purposes, for which they
are processed.
Your Steam ID is being processed for as long as you have an active account in the game.
If we process your personal data to determine or assert any claims or to defend against above
mentioned Customer’s claims (the legal ground for this action is our legitimate interest, we store the
personal data until the laps of the limitation period for those claims, which arise from the generally
applicable provisions of law.
If we process your personal data to comply with our legal obligation, we store the personal data for
a period of performing such obligation.
If we process your personal data on the basis of your consent, such data is being processed until the
withdrawal of your consent or by the time the purpose, for which it was collected, ceases to exist.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA?
If we ever collect your Personal Data you can rest assured that the access to your personal data will
be granted only to:
● authorized employees and co-workers, who are obliged to keep them secret and not to use
them for purposes other than those for which we have collected them,
● entities that support us in service providing, based on appropriate contracts e.g. legal,
consulting, telecommunication service providers.
All these entities will have access only to necessary information.
Please also be aware that while you are playing the game in multiplayer mode, other players will be
able to see your Steam ID or - as long as your Steam profile is public - other information shared by
you on your public Steam profile.
Sometimes, the entities providing us with solutions are registered outside the European Economic
Area (EEA). In this case, if your personal data is processed outside the EEA, we will provide the
appropriate legal mechanisms for their security, including standard data protection clauses adopted
under the decision of the European Commission, and - if necessary - we conclude data processing
agreements that meet the requirements of the GDPR. You have the right to access the list of such
recipients and a copy of the security measures we use. If we do not provide adequate security
measures, we will inform you about it and ask for your consent to transfer such data. Without
adequate protection or possible consent, we will not undertake the transfer of your Personal Data
outside the EEA.
We may also be required to provide specific information relating to you, to public authorities for the
purposes of proceedings conducted by them. In this case, the information is provided only if there is a
proper legal ground.
5. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
Every Customer has the following rights:
1. Right of access. In any time, you can obtain from us confirmation as to whether or not your
personal data are being processed, access to the personal data and the following information:
● the purposes of the processing;
● the categories of personal data concerned;
● who are the recipients;
● where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period;
● where the personal data are not collected from the data subject, any available information as
to their source;
● the existence of automated decision-making, including profiling, and, at least in those cases,
meaningful information about the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject.
2. Right to rectification. If you feel that the information relating to you is incorrect or incomplete, you
have the right to request the rectification of the data.
3. Right to withdraw the consent. you can withdraw your consent at any time, without affecting the
legality of the processing, which was performing prior to this withdrawal.
4. Right to erasure (‘right to be forgotten’). The GDPR gives you the right to obtain from us the
erasure of all your personal data. We are obligated to make your request, only if one of the following
grounds applies:
● your personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed;
● you withdrew consent on which the processing is based and where there is no other legal
ground for the processing;
● you object to the processing and there are no overriding legitimate grounds for the
processing;
● you object to the processing for direct marketing purposes;
● the personal data have been unlawfully processed;
● the personal data have to be erased for compliance with a legal obligation in European Union
or Member State law to which the controller is subject;
● the personal data have been collected in relation to the offer of information society services
referred to in Article 8(1) GDPR.
5. Right to restriction of processing. You can also obtain the restriction of processing, where one of
the following applies:
● you contest the accuracy of the personal data – for a period enabling the controller to verify
the accuracy of the personal data;
● the processing is unlawful but you oppose the erasure of your personal data and you request
the restriction of their use instead;
● we no longer need your personal data for the purposes of the processing, but they are
required by you for the establishment, exercise or defence of legal claims;
● you have objected to processing – only until the dispute is resolved.
6. Right to data portability. You have right to receive your personal data in a structured, commonly
used and computer-readable format and have the right to transmit those data to another controller,
when:
● the processing is based on your consent or on a contract, and
● the processing is carried out by automated means.
7. Right to object. According to GDPR you have right to object:
● to processing of personal data, when it is necessary for the performance of a task carried out
in the public interest or in the exercise of official authority vested in Controller – on grounds
relating to your particular situation;
● to processing of personal data, when it is necessary for the purposes of the legitimate
interests pursued by Controller or by a third party, except where such interests are overridden
by the interests or your fundamental rights and freedoms which require protection of personal
data, in particular where the data subject is a child, including profiling – on grounds relating to
your particular situation;
● at any time – to processing of personal data for direct marketing purposes, which includes
profiling to the extent that it is related to such direct marketing;
● to processing of personal data for scientific or historical research purposes or statistical
purposes – on grounds relating to your particular situation.
If, in spite of the Customer's objection, we consider that there are important, legally valid grounds for
processing personal data, which override the Customer's interests, rights and freedoms, we can
continue processing the Costumer’s personal data.
If you disagree with above mentioned Controller’s situation assessment, you have the right to lodge a
complaint with a supervisory authority (for more information, see point VII below).
8. Right to lodge a complaint with a supervisory authority. Due to our actions as a Controller, you
have the right to lodge a complaint with a supervisory authority, in particular in the Member State of
your habitual residence, place of work or place of the alleged infringement.
If you want to lodge a complaint in Poland, since 25th May 2018 the function of the supervisory
authority is held by the President of the Data Protection Office / Prezes Urzędu Ochrony Danych
Osobowych (PUODO). A detailed description of the procedure for lodging a complaint to PUODO is
available on the website maintained by PUODO which you can access by clicking the following link:
https://uodo.gov.pl/.