Protagonist s.r.o. (“Protagonist” or “we”) respects the privacy of Protagonist Platform users and is committed to comply with all applicable legislation on the protection of privacy, including, without limitation, the European Union General Data Protection Regulation (“GDPR”).
Wherever we talk about personal data below, we mean any information relating to an identified or identifiable natural person. We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Protagonist may share anonymous data, aggregated or not, with third parties.
Protagonist provides a social network and an online platform available at the www.protagonist.gg, aiming to connect the world's game industry professionals to allow them to be more productive and successful an online platform that offers a variety of services to its user. In particular you, as an user, may browse the publicly available content, post and share content of your own (e.g. pictures, videos, books, games, music), you may subscribe to certain content and services, offer to do work for hire, fund or buy the offered work and also create and manage a community page (the “Protagonist Platform”).
- 1 CONTROLLER OF THE PERSONAL DATA
The controller of your personal data is Protagonist s.r.o., residing at Prague 1, Jungmannova 23/11, post code 110 00, Czech Republic, Company Id. No (IČO): 069 31 871, registered in the Commercial Register, kept with Municipal Court in Prague in Section C Entry No. 291570.
E-mail address: [email protected]
- 2 PURPOSES OF DATA PROCESSING
We generally process your personal data for the following purposes:
- 2.1 Registration and Administration of Your Account.
- 2.1.1 For using the Protagonist Platform, you first need to register and set up your Protagonist account (the “Protagonist Account”).
- 2.1.2 When setting up Protagonist Account, Protagonist collects your email address and country of residence; you are also required to choose a user name and a password. During the setup of your Protagonist Account, the provided information is pseudonymized as the account is automatically assigned a number (the “Protagonist User ID”) which is later used to reference your Protagonist Account without directly exposing your personal data. We do not require you to provide or use your real name for the setup of a Protagonist Account.
- 2.1.3 The minimum age to create a Protagonist Account is 18. Protagonist will not knowingly collect personal data of children under this age.
- 2.2 Payments processing.
- 2.2.1 If you use the Protagonist Platform for purchases (e.g. to purchase Tokens and fund your Protagonist Wallet), we collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information, other account and authentication information, and billing, delivery and contact details. This information is processed by and transmitted to the payment service provider to enable the transaction and perform any anti-fraud or anti-money laundering checks required by applicable law.
- 2.3 Use of Protagonist Platform.
- 2.3.1 We collect the content, communications and other information you provide when you use the Protagonist Platform, including when you sign up for a Protagonist Account, create or share content and message or communicate with others. This can also include information in or about the content that you provide (e.g. metadata), such as the location of a photo or the date a file was created. This data includes particularly:
- (i) content that you share and make publicly available on the Protagonist Platform such as your comments, pictures, videos, games, music, books, feedback etc. (the “User Content”);
- (ii) information you provide when you request information or support from us or subscribe to content and services, including information necessary to process your payments and orders;
- (iii) information you voluntarily provide to us when participating in competitions, contests or responding to surveys, e.g. your contact details;
- (iv) information about how you use the Protagonist Platform, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you are using and have last used the Protagonist Platform, and what posts, videos and other content you view or use on the Protagonist Platform;
- (v) information about your browser and other device information.
- 2.3.2 We use this information to deliver the Protagonist Platform. We may also use some of your information to develop Protagonist Platform and to improve the overall Protagonist Platform user experience (e.g. by displaying relevant or suggested content).
- 2.4 Security. We use the information that we have to verify accounts and activity, prevent harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of the Protagonist Platform, and promote safety and security on the Protagonist Platform. For example, we use data that we have to investigate suspicious activity or breaches of our terms or policies, or to detect violations or breaches.
- 2.5 Communication with you. We use the information that we have to communicate with you about the about the availability of the Protagonist Platform, security, or other service-related issues and other changes which are important for your use of the Protagonist Platform and/or other services. We also use your information to respond to you when you contact us.
- 2.6 Newsletter and marketing.
- 2.6.1 Based on your consent, we may use your personal data to send you our newsletter or other marketing communications. These services are primarily comprised of provision of information about our latest offers, promotional activities and other information (including marketing communication).
- 2.7 Cookies. We use “Cookies”, which are text files placed on your computer, to help us analyze how users use the Protagonist Platform, and similar technologies (e.g. device identifiers, ad tags) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics, or website functionality. We use the Cookies according to the terms of our [link: Cookies Policy].
- 3 LEGAL GROUNDS AND RETENTION PERIODS
- 3.1 We carry out the processing activities pertaining to your personal data only to the extent and for the duration necessary to fulfill the purpose for which the information is collected and processed or – where the applicable law provides for longer storage and retention period – for the storage and retention period required by law. After that your personal data will be deleted or anonymized, as provided by applicable law.
We process your personal data on the basis of legal grounds specified below.
- 3.2 Performance of contract
- 3.2.1 The processing of your personal data is a necessary prerequisite for your use of Protagonist Platform, maintenance of your Protagonist Account and for us to meet our contractual obligations to provide its services. We process your personal data in order to ensure compliance with our terms of service and to enable you to take full advantage of all functionalities offered by Protagonist Platform.
- 3.2.2 When we process your personal data for the performance of a contract that you have entered into with us, the duration of the processing is limited to the duration of the contract, i.e. the duration of your Protagonist Account. If you terminate your Protagonist Account, your personal data will be marked for erasure; however, in certain cases we may continue to process your personal data even if the contract is terminated, in particular, if we are required to do so under applicable legal regulations, or if we have legitimate interest on the processing, such as establishment and enforcement of our legal claims.
- 3.3 Compliance with legal obligation
- 3.3.1 Processing of your personal data may be required for fulfilment of our statutory obligations, namely in relations to tax and accounting regulations. The applicable retention periods which we are obliged to follow are stipulated by law.
- 3.3.2 Protagonist is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
- 3.4 Legitimate interest
- 3.4.1 We may process your personal data on the basis of our legitimate interest:
- (i) to create, provide, support and maintain innovative products and features that enable people to express themselves, communicate, discover and engage with information and communities relevant to their interests, build community, and utilize tools and features offered by Protagonist Platform;
- (ii) to secure our Protagonist Platform, to verify Protagonist accounts and their activities, combat harmful conduct, detect and prevent spam and other bad experiences, keep the Protagonist Platform free of harmful or inappropriate content, and investigate suspicious activity or violations of our terms or policies;
- (iii) to engage in direct marketing practices to promote Protagonist Platform and other Protagonist services; and
- (iv) to prevent and address fraud, unauthorized use of the Protagonist Platform and other Protagonist services, violations of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
- 3.5 Consent
- 3.5.2 When you give us your consent, we keep your personal data only for the duration of the given consent, i.e. at maximum for 3 years, or until you decide to withdraw your consent. You have the right to withdraw your consent at any time. For more details on consent withdrawal, please see Section 6.4 below.
- 3.5.3 If you withdraw your consent or your consent expires, we will delete and/or cease to use your personal data without undue delay to the extent that the collection and processing of the personal data was based on that consent.
- 4 SHARING AND TRANSFER OF PERSONAL DATA (RECIPIENTS OF PERSONAL DATA)
- 4.1 User Content that you share
- 4.1.1 When you share and communicate your User Content using the Protagonist Platform, the User Content you share may be publicly available to other users of the Protagonist Platform.
- 4.1.2 Protagonist includes cards and comments areas, where users can exchange ideas and communicate with each other. When creating, editing a card, posting a message on a card or in a commenting section, please be aware that the information is being made publicly available online on the Protagonist Platform. If your personal data is posted on one of our community against your will, please contact Protagonist to request its removal.
- 4.1.3 You may also share your User Content with our partners, game developers and publishers. This information includes as a minimum your participation at their Protagonist community pages. Depending on the partner, it may include your level of participation and the type of interaction (pledge, community, social media sharing).
- 4.2 Sharing personal data with third-party partners
- 4.2.1 Some categories of the personal data that we collect in the manners set out above may be shared by us with third parties that provide certain services relating to the administration and execution of our contractual relationship, utilization of software resources, or protection of our legitimate interests. In particular, we may share your personal data:
- (i) with entities administering our IT systems and providing IT services and telematics utilized in the administration of Protagonist Platform;
- (ii) with external legal consultants for the protection of our legitimate interests;
- (iii) with public authorities or other third parties for the fulfillment of obligations in accordance with legal regulations.
- 4.2.2 In the event of a reorganization, sale or merger we may transfer personal data to the relevant third-party subject to applicable laws.
- 5 DATA SECURITY
We have deployed and maintained appropriate technical and organizational measures, internal controls and information security processes in accordance with best business practices corresponding to the possible impending risk to you as the data subject.
At the same time, we take into consideration the state of technological development with the goal of protecting your personal data from accidental loss, destruction, alterations, unauthorized disclosure or access. Such measures may, among other things, include taking reasonable steps to ensure the liability of relevant employees who have access to your data, training of employees, regular backups, procedures for data renewal and management of incidents, software protection for devices on which personal data are stored, etc.
- 6 YOUR RIGHTS AS A DATA SUBJECT
The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their personal data. While other jurisdictions may provide fewer statutory rights to their citizens, we make the tools designed to exercise such rights available to our customers. As a European Economic Area resident, you have the following rights in relation to your personal data.
Under the GDPR, you have the right have the right to request access to your personal data that we, as a personal data controller, are processing, the right to their rectification, erasure or portability (e.g., the portability of your personal data to another controller on the basis of your request), the right to object, as well as the right to request restriction of processing conducted by us. You can also withdraw consent to the processing of certain personal data at any time (e.g. our newsletter or other marketing services), if you have granted us such consent.
Learn more about these rights and find out how you can exercise your rights in your Protagonist Account settings (in the User Menu). While we review any request sent by mail, please be aware that to combat fraud, harassment and identity theft, some of your rights (such as access to, rectification or deletion of your data) is possible only in Protagonist Account settings (your User Menu).
- 6.1 Rectification of your personal data
According to applicable legislation, you have the right to rectify your personal data that we are processing if you find that they are inaccurate or incomplete.
- 6.2 Erasure of your personal data
You can request erasure of your personal data at any time. The scope within which we can comply with your request for erasure of personal data may be limited (i) as some of your data may be necessary for the provision of our service and your use of the Protagonist Platform and (ii) by our statutory obligations to store some personal data, particularly by accounting and tax regulations. Further, we will also erase all of your personal data (and ensure erasure thereof by the processors that we engage) if you withdraw your consent.
In certain cases, your personal data cannot be completely erased in order to ensure the consistency of the community experience on Protagonist. For instance, public comments you made on a community will not be deleted; rather, your comments will be permanently anonymized.
- 6.3 Withdrawal of consent
You can revoke your consent to the processing of certain personal data (e.g. newsletter or other marketing activities) at any time without giving reason. In such a case, we will erase your personal data within 8 days from the withdrawal of your consent.
Please note that the withdrawal of your consent does not affect the lawfulness of processing conducted on the basis of consent prior to its withdrawal.
- 6.4 Access to and Portability of your personal data
You have the right to obtain confirmation as to what personal data we process or do not process with respect to you and to obtain a copy of your personal data.
Should you request so, we can send some of your personal data (which we process on the basis of the fulfillment of a contract and/or your consent) directly to a third party (to another data controller) whom you state in your request, provided that such request does not affect the rights and freedoms of other persons, and provided that it is technically feasible.
- 6.5 Objection to processing
You have the right to object, at any time, to the processing of personal data based on our legitimate interest. If significant legitimate interests for processing - that override the interests or rights and freedoms of the data subject - are not proven on our part, or further processing is not necessary for the establishment, exercise or defense of our legal claims, we will no longer process your personal data.
If you exercise your right to object to processing of personal data for the purposes of direct marketing, we will immediately cease to process your personal data for this purpose.
- 6.6 Restriction of processing
If you request restriction of processing of your personal data, e.g. in the event that you question the accuracy or lawfulness, or our need to process your personal data, we will restrict the processing of your personal data to the necessary minimum (storage), and we may only process them for the establishment, exercise or defense of legal claims, or on grounds of the protection of the rights of another natural person or legal entity, or other limited reasons prescribed by applicable legislation. If a restriction of processing is lifted and we continue to process your personal data, we will inform you of without undue delay.
- 6.7 Complaint to the Office for Personal Data Protection
You have the right to lodge a complaint pertaining to processing of personal data conducted by us with the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Praha 7; website: www.uoou.cz.