Privacy policy

Privacy policy

CD PROJEKT RED STORE Privacy Policy
Last updated: 08/30/2019


Overview:

1. This document explains what data is collected in connection with CD PROJEKT RED STORE services.
2. It also explains how we use that data, where we store it, and how we protect it.
3. In short:
a. In order for you to use our services we need to process some of your data.
b. Should we need to process your data for any other purpose, we will always ask for your consent in advance.
c. Some partners, such as CD PROJEKT S.A., help us in providing our services and we may share limited data with them — but only for this purpose.
d. We will not share your data for third party advertising purposes.
4. Finally, it explains your rights in relation to your personal data.

Hello! This Privacy Policy is where we explain how your personal data is collected, stored or used, and what happens to it when you use CD PROJEKT RED STORE services. Like with our Terms of Use, we have put together two versions: a full text version, which is legally binding, and also section summaries, which will hopefully make the legal language a bit more accessible. If you have any questions, you can contact us at privacy-store@cdprojektred.com. Here we go!

FULL TEXT
QUICK SUMMARY
1. WHO WE ARE
1.1 We are CD PROJEKT, Inc., a Delaware corporation (hereinafter “CDP” or “we”). You may contact us via email atprivacy-store@cdprojektred.com or by mail: CD PROJEKT, Inc., 9A Wavecrest Avenue, Venice, California, 90291, USA.
Hello, we're CD PROJEKT RED STORE and we are based in California. You can find our contact details here!
2. WHAT THIS PRIVACY POLICY GOVERNS
2.1 This Privacy Policy applies to our online store CD PROJEKT RED STORE (further “Store”) directed to customers in the U.S., available at us.store.cdprojektred.com (including services connected with user registration, account, basket, order and payment processing, order history, wishlist, product reviews and comments) as well as customer service and technical support services connected with the Store.
This Privacy Policy explains the different kinds of data we collect from you when you use the Store services. We fully comply with privacy laws.
2.2 Specifically, this Privacy Policy governs personal data and non-personal data, which we collect from you when you use the Store services. ("Personal data" means data, which, on its own or in combination with other data, can be used to identify you).
2.3 We respect your right to privacy and will only collect, store and use personal data as necessary to allow you to use and purchase/receive products from the Store as more fully described herein.
3. PROTECTING CHILDREN
3.1 We recognize we have a special obligation to protect personal data obtained from children. We do not and will not knowingly collect personal data from any child under 13. If for any reason we decide to collect personal information of minors between the ages of 13 and 18, we will ask for their parent or guardian’s consent. If you are a parent or guardian and are concerned about the transfer of your child’s personal information, please contact privacy-store@cdprojektred.com.
We cannot and will not knowingly collect personal information about children under 13.
4. INFORMATION WE COLLECT
4.1 When you use Store services, we may collect the following data if relevant (how we use it is described later in this document).

In the context of order handling and customer accounts, we will process your basic personal data such as:
a. your name and surname;
b. email address;
c. residence address;
d. shipping address;
e. phone number;
f. IP address;
g. country, where you place your order;
h. order and payment history (including identifiers, order values and ordered items);
i. data resulting from your use of Store functionalities and optional data which you may provide in account settings (favorite items list, account settings, product reviews and ratings, day and month of your birthday, gender);
j. additionally — if you place your order as part of your business activity — invoicing address, business name.

Moreover, depending on the payment method you choose, we or a third party payment processor on our behalf, will collect and process the following payment-related data (depending on the payment method you choose):

a. debit/credit card data — card number, name and surname of the card holder, validity date;
b. bank account number, name and surname of the account holder;
c. e-mail address linked to PayPal account.
In order for you to shop in our Store, we need some basic data about you, such as your name, surname and e-mail address (for full details, take a look at the text on the left).
4.2 If you take part in contests organized by CDP, we may additionally process data necessary for the purpose of holding contests, announcing their results and sending prizes to the winners, such as your correspondence address, phone number, identifiers in social media, image of yourself or your bank account number.
If you participate in contests organized by us, we may need some additional data about you.
4.3 We may also collect some non-personal, anonymous data about our users (statistical information on the use of our services, information on devices used to connect to them, information about the websites you visited before and after coming to the Store) in order to better understand how our games, products and services are discovered and used and to improve them based on this knowledge.
We may also collect some statistical information on the use of our services.
4.4 In order for you to use our services, we need to process the data described above — providing this data is voluntary, but without it, you will not be able to use our Store or our services.
The above data is necessary for us to provide our services to you.
4.5 We and our partners also collect data about you via cookies. You can find out more about this in our Cookie Policy. The Cookie Policy forms part of this Privacy Policy.
Check our Cookie Policy to find out what sorts of cookies we use to support our services.
5. HOW WE COLLECT YOUR INFORMATION
5.1 We collect information you provide to us in the following ways:

a. When you request or purchase products, services, or information from us, register an account with us (including when you link your profile on a third-party site or platform with your registration account), participate in comment sections, forums, or other interactive features we provide, or otherwise interact with us using one or more devices.

b. Through the use of a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered. Please visit our Cookie Policy to learn how to disable cookies and otherwise make choices with respect to such data collection.

c. Through the use of analytics tools, including when you visit our Store and applications or use our applications on third-party sites or platforms
We collect your information when you provide it to us or through the use of technologies that collect non-personal data based on your use of the Store.
6. HOW YOUR INFORMATION IS USED
6.1 Your data may be used for the following purposes:

a. providing access to Store services, including account registration and personalization, order history and status, favorite items list, product review and comments functionalities;
b. organizing contests, including contacting participants, evaluation of applications, distribution of prizes, payment of tax on prizes;
c. sale and delivery of goods and payment handling;
d. calculating sales taxes owed (if any)
e. preventing payment fraud in the use of Store services;
f. providing technical support and customer service, as well as providing information about changes regarding goods and services of the Store;
g. monitoring operations of Store services and introducing improvements based on submitted remarks and suggestions;
h. in applicable cases – for the purposes of asserting claims and legal defense, including litigation, arbitration or mediation;
i. fulfilling the obligations resulting from provisions of law, including tax and accounting law;
j. documenting personal data processing for accountability purposes;
k. providing you with marketing information (including personalized and targeted marketing emails), which we feel may interest you. For example, we may send you newsletters or emails about our services (of course, this is optional and we will not send you any such correspondence without first getting your permission).
We collect your data to provide Store services to you and improve them, as well as to communicate with you and ensure your security in the payment process.
6.2 Your data may be used for the following purposes:

Whenever we personalize or target our marketing communications, offers and advertisements, we may profile your personal data, which means that we may use the data we collect to adjust the communication addressed to you to meet your needs or to attempt to ensure the communication is of interest to you.

If you decide that you no longer wish to receive personalized offers or product recommendations from us, or any advertising news at all, you can withdraw your consent at any time by clicking the appropriate link in the footer of our communication, or by sending us a request at: privacy-store@cdprojektred.com .
We gather data about when and how you use Store services in order to offer you the best service and communication possible. You can opt out of receiving such communications.
6.3 Consent. If you are a Canadian resident, we will obtain your consent to collect, use and disclose your personal data in all cases. You can withdraw your consent at any time. However, withdrawal of consent is not retroactive.
7. HOW DO WE HANDLE YOUR PERSONAL DATA
7.1 Where do we store it? The data we collect from you is stored on secure servers of our Trusted Partners, as described below, located in Warsaw, Poland and Szczecin, Poland.
We will store your data on secure servers of our Trusted Partners. We will do our best to keep your data secure.
7.2 How long will we store your data? We will retain your personal data only for as long as needed in order to fulfill the purposes outlined in this Privacy Policy. In certain special cases, a longer retention period might be required by law, such as for tax reasons, accounting purposes or other legal requirements and obligations. When we no longer require your personal information in order to provide our Store-related services to you, we will either delete it or anonymize it. In particular:

a. we will keep data that is associated with the services you use for the duration of the agreement to access the services (ex. Store Terms of Use). Following account closure, the limited data that we collect about you will still be retained for an additional few years for tax, legal or accounting purposes;

b. if you contact us and do not use our services, we will retain correspondence with you as long as necessary to assist you, followed by a period necessary for legal or accountability purposes;

c. for marketing purposes, we will store data as long as we have valid consent, and in case of its withdrawal, we will remove it without undue delay and no later than within 10 days from the moment we receive your request to cease data processing.

In general, we will store your data until you use our services. After that, we may still use limited data about you for tax, legal or accounting reasons.
8. HOW WE SHARE YOUR DATA
8.1 We may share your data with the following Trusted Partners, who were engaged by us to help deliver our services and functionalities to you. Please rest assured that we always provide our partners with the minimum data necessary for them to achieve the purpose of their cooperation with us and they are obligated to only use your data for these limited purposes. They may have access to limited data about you and process it on our behalf for the purposes set out below:
a. CD PROJEKT RED STORE sp. z o.o. (Privacy Policy) – our partner from CD PROJEKT Group, who supports us in operating our Store, including marketing activities, record keeping and correspondence handling, legal and technical support, and customer service, as well as provides us with internal management and data-sharing tools;
b. IdoSell sp. z o.o. (Privacy Policy) – technical operator of our Store
c. third party payment processors;
d. third party providers of sales tax solutions (that help us determine the applicable sales tax on a transaction);
e.partners providing assembly and shipping services;
f. our partners who help us in data analysis by providing us with analytical tools;
g. our partners who help us manage our newsletters and email communications by providing us with email marketing tools;
h. our professional advisors who assist us with legal, tax, audit or accounting matters;
i. advertising partners for the purpose of personalized and targeted marketing (for example, to inform you via advertisements on websites you visit about our services you may enjoy).
We sometimes share data with our Trusted Partners. They usually take care of stuff like supporting Store services, processing payments, product shipping or marketing activities.
8.2 When required by law (including pursuant to a subpoena or court order), we may share your data with the police, the courts, or other government authorities (including your IP address and details of suspected unlawful or fraudulent activity such as unauthorized use of payment methods and security risk scores – so if, e.g. it seems for us your card was stolen, we can inform the police about it).
We may share your data if required by law.
8.3 We may share some aggregated and general non-personal data on user behavior (e.g. sales per region, number of reported technical issues) with third party partners who work with us to provide Store services to you (for example, producers of our gadgets or payment providers) in order to support, improve or amend Store services. We may also share non-personal data with data analysis services to help us run Store services. Everything is anonymized, so you cannot be identified.
We may share anonymous, non-personal data to support and improve our Store.
8.4 In the unlikely event of a reorganization or merger of CDP, we may transfer personal data to an involved third party who will ensure protection of at least the same level as what we ensure in this Privacy Policy.
In the event of any reorganizations, acquisitions, etc., your personal data will still be given at least the same level of protection as it is now.
8.5 Please remember that any communications you have via CDP services (e.g. reviews or comments published on product pages in the Store) may reveal details about you. Also, any data you post publicly using CDP services will be publicly available for Store users and others. We are not responsible for your use of any private personal data which you choose to make available via CDP services, or the activities of other users or other third parties to whom you give or make available your data.
When you use CDP services, you have the option to share your own personal data with others or publicly. Be aware that you are responsible for this type of data sharing.
9. SECURITY
9.1 We implement commercially reasonable technical and organizational measures to protect your personal data against unauthorized or unlawful access, accidental loss, destruction or damage. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
We will do our best to keep your data secure.
9.2 However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk.
Unfortunately, no security is perfect.
9.3 If you believe your personal data is being improperly used by us or any third party, please immediately notify us via email at privacy-store@cdprojektred.com
Please let us know if you think your information has been improperly used.
10. YOUR RIGHTS & OBLIGATIONS, INCLUDING OPTING OUT
10.1 We ask that you keep the personal data that you provide to us current and that you correct any information you have provided us by contacting us at privacy-store@cdprojektred.com. You represent and warrant that all personal data you provide us is true and correct and relates to you and not to any other person.
You agree to keep your personal data up-to-date and agree that it is true.
10.2 If you wish to review, delete and/or revise the personal data we have stored about you, please contact us with your specific request at privacy-store@cdprojektred.com; provided, however, that we reserve the right to retain an archive of such personal data for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such data.
Contact us if you want to review, delete or change the personal data we have about you.
10.3 You may have the ability to “opt in” to receiving promotional communications from us. If you initially decide to receive information from us but at a later date wish to remove your information from our database, you can do so by using the unsubscribe link at the bottom of our emails. You may also at any time opt out of receiving e-mails from us or affiliated or related companies by sending an e-mail to privacy-store@cdprojektred.com with the subject line “Opt Out.”

Please note that even if you unsubscribe from our promotional email messages, we may still need to contact you with important transactional information related to your account and your purchases. For example, even if you have unsubscribed from our promotional emails, we will still send you confirmation of a purchase you have made from our Store.
You can opt out of receiving any promotional communications from us.
11. YOUR CALIFORNIA PRIVACY RIGHTS
11.1 Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide detailed information regarding how that business has shared that customer’s personal data with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose personal data to third parties for direct marketing purposes without prior approval.
We do not share personal data with third parties for direct marketing purposes.
11.2 Web browsers can transmit Do Not Track signals that indicate that a user does not wish to have activity tracked. Currently, no universally accepted standard exists for how to interpret such signals and for that reason, as well as other technical reasons, we may not recognize browser Do Not Track signals.
We may not be able to interpret and adhere to Do Not Track signals.
12. YOUR CANADA PRIVACY RIGHTS
12.1 If you are a Canadian resident, you may exercise the following rights under Canadian privacy leglislation:

a. right of access and correction: we permit a reasonable right of access and review of personal data held by us and will endeavour to provide the data in question within a reasonable time, generally no later than 30 days following the request;

b. right to opt-out of the use or sharing of your data, including for the purposes of marketing and targeted advertisements: you may contact us to opt out of the use of your personal data for marketing purposes or the provision of your personal data to our business partners for such purposes.

c. right to complain to the regulator: we will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue. If we are unable to resolve your concerns to your satisfaction, you have the right to contact the appropriate federal or provincial Privacy Commissioner.
12.2 You may contact the federal Office of the Privacy Commissioner by writing to:

Office of the Privacy Commissioner of Canada,
30 Victoria Street
Gatineau, Quebec
K1A 1H3

https://www.priv.gc.ca/en/contact-the-opc/
13. THIRD PARTY INFORMATION COLLECTION AND EXTERNAL SERVICES
13.1 CDP services may, from time to time, contain links to and from the websites or services of third parties. Our Privacy Policy does not extend to these external sites or companies, so please refer directly to their privacy policies.
We may sometimes provide links directing you outside the Store — be aware that these places can have privacy policies which differ from ours.
14. CHANGES TO THIS PRIVACY POLICY
14.1 We may change this Privacy Policy if we deem it necessary, such as for legal reasons or to reflect changes in our services. If we do so, we will make the altered Privacy Policy available online, update the “Last Updated” date and notify you about the changes.
We may make changes to our Privacy Policy. Whenever we do, we will publish the changed version online and notify you.
15. TERMS OF USE
15.1 We would also like to remind you that our Terms of Use contain more information about CDP Services. You can read them here. The legal terms in our Terms of Use or incorporated into this Privacy Policy.
For more fun legal reading, please see our Terms of Use.
16. Questions? Concerns?
16.1 If you have questions or comments about this Policy, please contact us at privacy-store@cdprojektred.com.
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