workplays.it — this English translation is provided for convenience; the Polish version is legally binding.
I. General information
- This Privacy Policy is a set of rules intended to inform you about all aspects of the process of collecting, processing and securing your personal data. The Policy is addressed to all users (hereinafter: "Users") of the Administrator's Website.
- This Policy sets out the rules for the processing of personal data by the Personal Data Administrator, which is: WORKPLAYS IT SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, KRS: 0001097357, NIP: 7123473171, REGON: 528250745, ul. Związkowa 26, 20-148 Lublin, Poland (hereinafter: the "Administrator"). You can contact the Administrator about personal data matters by email at office@workplays.it or in writing at the registered office address.
- This Policy may be amended and updated in the event of changes in personal data processing practices (taking into account current case law and guidance of the Polish supervisory authority, PUODO) or changes in generally applicable law. The Administrator will inform Users about changes to the Policy on the Website. We encourage Users to read this Policy carefully and check this page regularly to verify changes the Administrator may introduce in accordance with its provisions.
- Using the Administrator's Website and the Electronic Services requires the User to read and accept this Privacy Policy and the Terms of Service.
- Providing personal data to the Administrator is voluntary but is a necessary condition for using the Website and the Electronic Services.
II. Definitions
- Administrator — the entity that decides how and for what purposes Personal Data are Processed. The Administrator is responsible for the compliance of processing with applicable data protection law.
- Personal Data — any information about an identified or identifiable natural person.
- Process, Processing or Processed — any operations performed on Personal Data, whether automated or not, such as: collecting, recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.
- Processor — any person or entity that Processes Personal Data on behalf of the Administrator (other than an employee of the Administrator).
- Website — https://workplays.it/
- The Administrator's fanpages and spaces on social media:
- Facebook — https://www.facebook.com/workplays.it
- YouTube — https://www.youtube.com/@WorkPlaysIT
- Instagram — https://www.instagram.com/workplays.it/
- Discord — https://discord.com/invite/ZFE4xZBxHH
- Electronic Services — services provided through the Website. The provision of Electronic Services to Users takes place under the conditions set out in the Terms of Service.
III. Processing of Users' Personal Data
- The Administrator may obtain Users' Personal Data in particular in the following cases:
- when Users provide Personal Data, on the basis of Art. 6(1)(f) GDPR (the Administrator's legitimate interest — replying to a message or enquiry) in connection with handling the reported matter or enquiry,
- when Users' Personal Data are obtained as a result of registration on the Administrator's Website, e.g. creating an Account and enabling its use, handling requests and complaints, in order to conclude and perform a contract, on the basis of Art. 6(1)(b) GDPR (performance of a contract / acceptance of the Terms of Service),
- to pursue claims and act in defence of the Administrator's rights, conduct court proceedings, and, among other things, enable the use of the Website via cookies, prevent fraud in the use of the Website and Electronic Services, in particular to operate, maintain, improve and provide all of its features, as well as to prepare summaries, analyses and statistics for the Administrator's internal purposes (reporting, marketing research, planning the development of the Website and Electronic Services, development work, opinion research, building statistical models) — on the basis of Art. 6(1)(f) GDPR (the Administrator's legitimate interest referred to above),
- when Users' Personal Data published on social media are obtained (e.g. information from Users' private social media profiles to the extent such information is publicly visible), on the basis of Art. 6(1)(f) GDPR (the Administrator's legitimate interest — promoting its own business and services, running a social media profile (fanpage), building and strengthening customer relations, conducting analyses and statistics on the profile's popularity and performance, as well as establishing, pursuing and defending against possible claims related to the use of the profile, responding to contact),
- when the User consents to the processing of the provided personal data, on the basis of Art. 6(1)(a) GDPR (consent), including consent to receive email notifications about new job offers (signing up in the notification centre or enabling notifications on the Account); notifications can be switched off at any time in the settings or with one click via the link included in every message,
- when Users' Personal Data are obtained, or Users are asked to provide them, during Users' visits to the Administrator's pages or when using any features or resources available on or through the Website — first-party and third-party cookies. When Users visit the Website, Users' devices and browsers may automatically share certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to the Website and other technical communication information), some of which may constitute Personal Data. During a visit to the Website no Personal Data of Users will be stored by the Administrator without an appropriate legal basis. As regards cookies, apart from strictly necessary ones, the Administrator will each time obtain the User's consent to install the remaining cookies (including third-party Google Analytics cookies). Granting this consent is optional and does not affect the ability to use the Website. Processing takes place on the basis of Art. 6(1)(a) GDPR (consent — for cookies other than the necessary ones) and Art. 399 of the Polish Electronic Communications Law (legal provision — for necessary cookies).
- Providing personal data is voluntary and is not a statutory obligation. In certain cases, however, without providing personal data it is not possible to use the Website or the Electronic Services. The categories of Users' Personal Data Processed by the Administrator may include in particular:
- personal details: first name(s), surname(s),
- contact details: company details, email address, phone number,
- message content: all messages (enquiries, statements, views and opinions) sent via the contact form or published on the Administrator's site or fanpages by the User,
- IP number, cookies and information on how our Website and Electronic Services are used — while using the Website or the Electronic Services,
- image: when publishing an opinion, leaving a comment or clicking "Like" on the Administrator's social media profile (fanpage), provided the User's image is shared on their private account on that platform,
- behavioural data (upon consent to Google Ads): information about the user's activity on websites, ad clicks, time spent on the site and interactions with content.
- The Administrator uses fanpage-type profiles on social media. Public data shared by social media Users may be used to:
- reply to private messages addressed to us,
- hold discussions in comments under individual posts,
- share our posts with people following our fanpage,
- for marketing purposes, i.e. informing about our services and about us through posts we publish on our fanpage, including sponsored posts displayed to a wider audience of Users,
- for statistical purposes, i.e. presenting data on the views, reach and number of interactions of our posts; the data presented to us by the social media platform owners are statistical data, but they are created based on observations of behaviour on our fanpage.
- The Administrator's Website currently uses redirects to the following social media platforms (fanpages): Facebook, Instagram, YouTube, Discord.
- When you like the Administrator's post, leave a comment, send a private message, subscribe to a channel or join the community, the Administrator, jointly with:
- Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland,
- Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Grand Canal Dock, Dublin 4, D04 V4X7, Ireland,
- Discord Inc., 444 De Haro Street #200, San Francisco, CA 94107, USA, EIN: 46-0850804
becomes a controller of your personal data shared on its fanpage to the extent of processing data for statistical and advertising purposes. - In this context we encourage you to read the privacy policies of: Facebook (https://www.facebook.com/privacy/policy/), Instagram (https://privacycenter.instagram.com/policy/), YouTube (https://policies.google.com/privacy), Discord (https://discord.com/privacy).
IV. Sharing Personal Data with third parties
- The Administrator may share Users' Personal Data with:
- persons authorised by the Administrator to process the data,
- entities entrusted with data processing, e.g. technical service providers and entities providing advisory services,
- other controllers, where required by law or in the good-faith belief that such action is necessary to comply with applicable law, in particular in response to a request of a court or state authorities.
- If we engage a third party to Process Users' Personal Data, under the data processing agreement concluded with such an entity the Processor will be obliged to:
- Process only the Personal Data indicated in the Administrator's prior written instructions, and
- apply all measures to protect the confidentiality and security of Personal Data and ensure compliance with all other requirements of generally applicable law.
- Due to the use of Facebook, Instagram or Discord services, data may be transferred by these entities to third countries — the United States of America (USA) — in connection with their internal sharing, among others with Meta Platforms Inc., over which the Administrator has no control.
V. Third-party services
- The Website may contain features or links redirecting to websites and services provided by third parties that are not managed by us. Information you provide on those sites or services will be subject to their own privacy policies and data processing procedures.
- The Administrator is not responsible for the processing procedures of independent website administrators and service providers.
- We encourage you to read the privacy and security policies of third parties before providing them with information.
VI. Data protection
- The Administrator has implemented appropriate technical and organisational measures to protect Personal Data, in particular safeguards against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unlawful and unauthorised forms of Processing, in accordance with applicable law.
- The Administrator is not responsible for the acts or omissions of Users. Users are responsible for ensuring that all Personal Data are transmitted to the Administrator in a secure manner.
- Personal data may be subject to profiling, i.e. automated decision-making concerning the User — decisions made by technical means without human involvement that produce legal effects for the profiled person or otherwise significantly affect them. The conditions of profiling within the Matchmaking feature are set out in the Terms of Service.
VII. Data accuracy
- The Administrator takes all adequate measures to ensure that:
- Users' Personal Data Processed by the Administrator are accurate and, where necessary, kept up to date,
- any Users' Personal Data Processed by the Administrator that are incorrect (having regard to the purpose of Processing) are erased or rectified without undue delay.
- The Administrator may at any time ask Users about the accuracy of the Processed Personal Data.
VIII. Data minimisation
The Administrator takes all adequate measures to ensure that the scope of Users' Personal Data it Processes is limited to the Personal Data adequately required for the purposes indicated in this Policy.
IX. International data transfers
Personal data may be shared and processed outside the European Economic Area (the European Economic Area comprises the European Union together with Iceland, Liechtenstein and Norway, jointly the "EEA"). If personal data are transferred outside the EEA, the Administrator requires appropriate safeguards. The Administrator will fulfil its obligations under Chapter V of the GDPR to ensure the lawfulness of such processing.
X. Use of the Pixel service
- By using the tracking Pixel service provided by Facebook, the Administrator becomes a joint controller of personal data with the service provider, i.e. Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland. The scope of joint processing / joint controllership covers: (1) collecting personal data and (2) transferring them to Facebook.
- The types of personal data covered by joint controllership with Meta Ireland in connection with the Administrator's use of the Pixel product on its website are:
- information in HTTP headers containing information about the browser or application used (e.g. user agent, country/locale),
- information about standard/optional events, e.g. "page view" or "app install", further object properties and buttons pressed by site visitors, depending on the configuration of the Business Tool,
- online identifiers, including IP addresses and, where provided, Meta-related identifiers or device identifiers (e.g. advertising identifiers in mobile operating systems) and information about opting out of / limiting ad tracking.
Further processing of data by Meta Ireland is not part of the joint processing with the Administrator. - Third parties, including Meta, may use cookies, web beacons and similar technologies to collect or receive information from the website and elsewhere on the internet and use it to provide measurement, targeting and ad delivery services. You can opt out of the collection and use of information for ad targeting — details: https://www.facebook.com/business/help/165516217407801. You can also use choice mechanisms at http://www.aboutads.info/choices and http://www.youronlinechoices.eu/
- We encourage you to read Meta's joint controllership terms (https://www.facebook.com/legal/controller_addendum), the terms of the Pixel product (https://www.facebook.com/legal/terms/businesstools) and the mechanisms allowing Users to make choices about the scope of processing.
XI. Personal data retention period
- The criteria determining the period for which the Administrator stores Users' Personal Data are as follows: the Administrator keeps copies of Users' Personal Data in an identifiable form only for as long as necessary to achieve the purposes indicated in this Policy, unless generally applicable law requires a longer retention period. In particular, the Administrator may retain Users' Personal Data for the entire period necessary to establish, exercise or defend claims (limitation of claims under Art. 118 of the Polish Civil Code).
- Personal data are stored:
- for 30 days from the moment of contact (phone, email from the website); personal data may be processed for a longer period if, as a result of the enquiry, the User decides to use the Administrator's services (an Account on the Website, conclusion of a contract),
- where our services are used (an Account on the Website, conclusion of a contract) — for the period of performing the contract, holding the Account and the period necessary to handle complaints, until any disputes are resolved and the parties are settled, taking into account the applicable limitation periods for claims,
- for the Administrator's internal administrative purposes and other processing purposes based on the Administrator's legitimate interest — until the legitimate interests of the Administrator constituting the basis of the processing are fulfilled or until an earlier objection to such processing is raised, after the Administrator has duly weighed the User's interest against the Administrator's grounds for processing,
- for data processed on our fanpage — until an objection to further processing is raised by clicking "unlike", withdrawing the like of a post, deleting a comment or cancelling a subscription.
XII. Google Analytics and Google Ads
- The Administrator uses the Google Analytics tool provided by Google LLC, whose infrastructure is located at Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Administrator notes that Google LLC (1600 Amphitheatre Parkway, Mountain View, California 94043, USA) has joined the EU-US Data Privacy Framework, i.e. ensures an adequate level of security of personal data processing in accordance with the GDPR.
- Google Analytics allows:
- tracking site traffic: information about the number of users, number of visits, traffic sources (e.g. ads, search engines, social media),
- monitoring user behaviour: analysing which pages are visited most often, time spent on the site, bounce rate,
- user segmentation: demographic, geographic and technological data (e.g. device type, browser),
- tracking goals and conversions: analysing how users complete specific actions, such as purchases or downloading materials.
- Google Analytics processes data that may include:
- IP addresses — used to identify users' geographic location, which combined with other data may constitute personal data,
- cookies — storing unique user and session identifiers, enabling tracking of their activity, only after the User has given the appropriate consent,
- technical data — e.g. browser type, operating system, screen resolution, internet service provider.
- The Administrator uses the IP anonymisation feature, which prevents identification of Users (the last octet of the IP address is masked before the data are stored or processed).
- The Administrator processes data using this tool to provide analyses and reports on site traffic and the effectiveness of marketing activities, on the basis of the Administrator's legitimate interest and the User's consent (acceptance of Google Analytics cookies). The Administrator has concluded an appropriate Data Processing Agreement with Google governing data security as required by law.
- The Administrator uses Consent Mode, which allows measuring traffic and conversions on the Website even when the User does not consent to cookies, while maintaining full GDPR compliance. A tracking code is implemented that collects only basic, anonymised and aggregated data about the time of the visit, referrer information and conversion measurement for ad campaigns. If the User consents to specific types of processing (Google Analytics cookies), the relevant tags operate in full. Without consent, the tools still work in a limited mode, collecting anonymous data without any possibility of identifying the User. Consent Mode helps meet the requirements of the GDPR and the ePrivacy Directive, respecting Users' cookie consent decisions.
- The retention period for data collected upon acceptance of Google Analytics cookies is 14 months.
- We encourage you to read Google's Privacy Policy: https://policies.google.com/privacy
- You can configure your browser to block cookies related to Google Analytics. Google Analytics uses cookies such as _ga, _gid and _gat.
- You can also use a plugin blocking Google Analytics. Google offers a browser add-on that blocks Google Analytics, available at: https://tools.google.com/dlpage/gaoptout. Once installed, the plugin prevents data from being sent to Google Analytics from all visited sites.
- The Administrator also uses Google Ads tools. Upon consent to the use of this tool, Users' Personal Data are processed to display personalised ads on Google platforms and partner sites, analyse the effectiveness of ad campaigns, perform remarketing (displaying ads to users who visited the advertiser's website) and optimise ad content based on users' preferences.
XIII. Users' rights
- In connection with the processing of personal data you have the following rights:
- the right of access to the processed personal data — on this basis the Administrator, at the request of the data subject, provides information about the processing of their personal data, including above all the purposes and legal bases of processing, the scope of data held, the entities to whom the personal data are disclosed and the planned date of their erasure. As part of the right of access, the data subject may also request information about with whom their personal data are shared and whether they are subject to profiling and automated decision-making. The data subject also has the right to obtain a copy of their data,
- the right to rectification — on this basis the Administrator, at the request of the data subject, removes any inconsistencies or errors in the processed personal data and completes or updates them if they are incomplete or have changed,
- the right to erasure — on this basis the Administrator, at the request of the data subject, erases data whose processing is no longer necessary for any of the purposes for which they were collected, where consent to their processing has been withdrawn or an objection has been raised, and where retention is not required to establish, pursue or defend the Administrator's claims,
- the right to restriction and portability of processing — on this basis the Administrator, at the request of the data subject, ceases operations on the personal data to the extent consistent with the law, and releases the personal data in a machine-readable format,
- the right to lodge a complaint — a person who believes their personal data are processed unlawfully may lodge a complaint with the President of the Personal Data Protection Office (PUODO, ul. Stawki 2, 00-193 Warsaw, Poland),
- the right to object — the data subject may at any time object to the processing of personal data for the purposes for which they were collected and are processed,
- the right to withdraw consent — if we process personal data on the basis of consent, the data subject may withdraw that consent at any time. Withdrawal of consent does not render the processing carried out before the withdrawal unlawful — it does not affect the lawfulness of processing to date, but means the personal data will no longer be used for those purposes from the moment of withdrawal.
- A request concerning the exercise of the rights described above can be submitted by traditional mail to the Administrator's registered office address or by email: office@workplays.it
- The request should, as far as possible, precisely indicate what it concerns, in particular its addressee and which of the rights described above the person submitting the request wishes to exercise. If the Administrator is unable to determine the content of the request or identify the person submitting it based on the submission, it will ask the applicant for additional information.
XIV. Cookies
- When the User uses the Website, data about the User are collected automatically. These data may include: IP address, domain name, browser type, operating system type.
- These data may be collected by: cookies, Google Analytics, the Pixel service, and may be recorded in server logs.
- Cookies are small text files stored by the browser on your computer's hard drive or on a smartphone's memory card. On subsequent visits to the website, the information stored in the cookie is sent back to the Website. This allows the Website to recognise you and tailor content to your needs.
- We may use cookies to improve our Website and Electronic Services, deliver the most relevant content and analyse how Users use our Website.
- We may process data contained in cookies for the purposes of:
- personalising the Website and Electronic Services: remembering information about the User so that the User does not have to re-enter it on subsequent visits,
- delivering ads, content and information tailored to the User,
- monitoring aggregate site usage metrics, such as the total number of visitors and page views.
- We use the following types of files:
- session cookies, which are temporary files stored on the visitor's device until they leave the Website,
- persistent cookies, which are stored on the visitor's end device for the time specified in the file's parameters or until manually deleted.
- Cookies can be divided into the following categories:
- necessary cookies — contribute to the usability of the site by enabling basic functions such as page navigation and access to secure areas of the website; the website cannot function properly without them,
- statistical cookies — help website owners understand how different users behave on the site by collecting and reporting anonymous information (consent given in the cookie settings),
- preference cookies — allow the site to remember information that changes the way the site looks or behaves, e.g. the preferred language or the user's region (consent given in the cookie settings),
- marketing cookies — used to track users across websites in order to display ads that are relevant and interesting to individual users (consent given in the cookie settings),
- unclassified cookies — files that are in the process of being classified together with the providers of individual cookies.
- We use analytics and similar services that include third-party cookies. While using the Website, third-party cookies may be used to enable the functionality of the Website and integrated sites, or to analyse the effectiveness of advertising campaigns and collect anonymous statistical information about the use of the Website.
- This Privacy Policy does not govern the use of third-party cookies. Each third party sets its own cookie rules in its privacy policy.
- The site uses Google Analytics. You can prevent Google from recording the data collected by cookies about your use of the Website, and from processing those data, by installing the browser plugin available at: https://tools.google.com/dlpage/gaoptout
- You can change the scope of your cookie consents at any time using the "Cookie settings" option available in the Website footer.
- Please note that refusing consent, deleting, blocking or limiting the placement of cookies may cause difficulties or even prevent the use of the Website or the Electronic Services.