Gamesture
Privacy Policy

Privacy Policy
Gamesture

Effective Date: 23 October 2023
This Privacy Policy applies to Gamesture's games, websites, stores and related services, which we here collectively call the "Services". We may periodically update this Privacy Policy by posting a new version on gamesture.com. If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Services prior to the change becoming effective. Your continued use of the Services after the effective date will be subject to the new Privacy Policy.
Personal Data Controller The personal data controller is Gamesture sp. z o.o, ul. Grodziska 8, 60-363 Poznan Poland e-mail: privacy@gamesture.com (hereinafter referred to also as "us", "we" or "Gamesture").
Information on the processing of personal data Gamesture processes personal data in accordance with the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 /EC (hereinafter referred to as a "GDPR").
Data Protection Officer Gamesture has appointed a Data Protection Officer who can be contacted by e-mail at privacy@gamesture.com and by correspondence to Gamesture's address with the addition "DPO".
Data Protection Officer: Katarzyna Ułasiuk - Delamare
Why and which data We collect The type of personal information we gather is based on the Services you utilize and legal mandates that apply

Data Provided Directly by You:
  • Contact information (such as name, email address, or phone numbers);
  • Player name or tag and password;
  • Profile information;
  • Your messages and other content submitted through the Services (such as chat logs, player support tickets);
  • Data provided for surveys, promotions, sweepstakes, competitions, and events;
  • Data connected to all purchases made in our store and in external stores (like AppStore or Google Play);
  • Any other data you choose to give us.

Data Collected Automatically:
  • Data about your account and game progress, including in most cases an automatically created internal account ID;
  • Your IP address and mobile device identifiers (such as device or advertising ID);
  • Data about your device (such as device name, operating system, browser type and language, internet service provider, and mobile carrier);
  • Data collected with cookies and similar technologies;
  • Approximate location data (based on IP address);
  • Data about your use of the Services (such as gameplay data, purchases, and interactions with other players).

Data Collected from partners:
  • Data received if you link a third-party tool with the services (such as Facebook or Google);
  • Demographic data (to determine your IP address's location);
  • Data to fight fraud (such as refund abuse in games or click fraud in advertising);
  • Data from platforms where the games run or data from payment service providers (such as payment verification data);
  • Data for advertising and analytics purposes to provide a better Services;
  • Data made available to us from a third-party services (such as Google or Facebook) via your privacy settings.

We use data for a variety of business purposes, such as:

To make the Services work To perform the contract, we process data necessary to:

  • Create accounts and allow you to play our games and use our Services;
  • Operate the Services;
  • Verify and confirm payments;
  • Provide and deliver products and Services you request;
  • Send you Services-related communications.

We base the processing of that data on Article 6, section 1, point b of the GDPR (to execute the contract and deliver our products and Services) and Article 6, section 1, point f of the GDPR as it is our legitimate interest (to keep the Services safe and fair, for the purposes of internal analysis and statistics, service optimalization and improvement for after-sale care and to establish, pursue and defend against claims).

To make the Services more suitable for our players To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to:

  • Update and develop player profiles;
  • Develop and improve the Services and player experience;
  • Manage our relationship with you;
  • Provide social features as part of the Services;
  • Customize your Services experience;
  • Respond to your comments and questions and provide player support;
  • Provide you Gamesture offers in the Services;
  • Send you related information, such as updates, security alerts, and support messages;
  • Enable you to communicate with other players.

We base the processing of that data on Article 6, section 1, point a of the GDPR (Your consent) Article 6, section 1, point b of the GDPR (to execute the contract and deliver our products and services) and Article 6, section 1, point f of the GDPR as it is our legitimate interest (to keep the Services safe and fair, for the purposes of internal analysis and statistics, to market our products, for service optimalization and improvement, for after-sale care and to establish, to pursue and defend against claims).

To show personalized advertisements To show you personalized advertisements in the Services as well as in other websites and services (including email) we have a legitimate interest to process necessary data to:

  • Track the content you access in connection with the Services and your online behavior;
  • Deliver, target and improve our advertising and the Services.

We base the processing of that data on Article 6, section 1, point a of the GDPR (Your consent), Article 6, section 1, point f of the GDPR, as it is our legitimate interest (to present personalized advertisements, for the purposes of internal analysis and statistics, service optimalization and improvement and to pursue and establish, pursue and defend against claims).

To keep the Services safe and fair To keep the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

  • Analyze and monitor use of the Services and its social features;
  • Moderate chats either automatically or manually;
  • Act against fraudulent or misbehaving players.

We base the processing of that data on Article 6, section 1, point f of the GDPR, as it is our legitimate interest (to keep the Services safe and fair, for the purposes of internal analysis and statistics, service optimalization and improvement for after-sale care and to establish, pursue and defend against claims).

To analyze, profile, and segment In all of the above cases and purposes, we may analyze, profile and segment all collected data.

We base the processing of that data on Article 6, section 1, point f of the GDPR, as it is our legitimate interest (to analyze, profile and segment data for our internal purposes such as service optimalization and improvement, for the purposes of internal analysis and statistics, for after-sale care and to establish, pursue and defend against claims).

Contact We handle personal information in order to communicate with individuals who reach out to us through phone, email, or traditional mail. This includes answering questions, providing information, responding to inquiries, and sending requested materials. This is our legitimate interest as stated in Article 6, section 1, point f of the GDPR.
We retain the data used for communication purposes until the communication has been completed or the questions have been answered, and then until the end of the calendar year following the resolution or end of the communication. We keep the correspondence for this period of time for evidentiary purposes and to support or defend against potential claims, which is our legitimate interest as stated in Article 6, section 1, point f of the GDPR. When sending us an email or making phone inquiries, please only provide the necessary information.

Social media We run profiles on the following social networks:

  • Facebook
  • LinkedIn
  • Instagram
  • TikTok

We base the processing of that data on Article 6, section 1, point f of the GDPR, as it is our legitimate interest (to run our social media accounts, for the purposes of internal analysis and statistics, for after-sale care and to establish, pursue and defend against claims). The abovementioned social media platforms are joint data controllers, and have their own Privacy policies.

Webstore We handle personal information in order to enable You to make purchases of in game assets. Those purchases can be made with the use of our internal Webstore (at www.store.gamesture.com) or with the use of external stores (like AppStore or Google Play). This includes acceptance and execution of the order, payment, and after sales care. We base the processing of that data on Article 6 section 1 point b of the GDPR (to execute the contract), Article 6 section 1 point c of the GDPR (to fulfill our tax and accounting obligations) and also on Article 6, section 1, point f of the GDPR, as it is our legitimate interest (to execute the contract, for the purposes of internal analysis and statistics, for after-sale care and to establish, pursue and defend against claims).
We retain data connected to purchases made from us for the time required by the appropriate tax and accounting laws or until any potential claims expire (whichever is longer).

To reach out to its users and present content on these portals created by Gamesture, promote its activities (including informing about new events), as well as for analytical and statistical purposes, which serve the legitimate interest of the company in connecting with portal users and promoting and informing about its activities. Through the portals, we may also host contests that users can participate in voluntarily. We process the personal data of portal users when they visit our profiles or interact with them (likes, comments, direct messages). If you like or comment on our posts, please keep in mind that it will be visible to other users. We will retain personal data until you object to its further processing by clicking "I don't like", withdrawing the like from the post, or removing the comment from the post, and then for the duration required by legal obligations and/or until the expiration of the time limit for any claims related to the processing purposes.
Voluntary data provision While giving us your personal information is not mandatory, it may be required if you wish to access certain features or Services we offer.
Automated decision making, including profiling We do not use automated processing or profiling of personal data to make decisions through our websites.

When you use our games, we collect information about your in-game activity and interactions with other players through server log files. This information helps us create personalized advertisements and offers, maintain the safety of our Services, and analyze and monitor your usage to improve our games.

We may also use this information to make automated decisions about the content of advertisements and offers based on your behavior and data. The legal basis for this processing is our binding agreement for providing Services and our legitimate interests.
If your data is being processed for profiling purposes that align with our legitimate interests, you have the right to object to this processing at any time, considering your specific situation. In this case, Gamesture cannot process your data unless they can demonstrate compelling legitimate reasons that override your interests, rights, and freedoms, or if it is necessary for the establishment, execution, or defense of our legal claims.

If we use your data for the purpose of direct marketing through profiling, you have the absolute right to object to this processing at any time. In this case, your personal data will no longer be processed for this purpose, regardless of our interests, rights, and freedoms.
International data transfers Our Services operate globally, which means that your data may be transferred to any location around the world. This can result in your data being subject to different data protection laws than the ones in your country. To ensure that your data is protected, we have put in place adequate safeguards such as standard contractual clauses approved by the EU Commission and other lawful methods.
Who can access your data Apart from Gamesture, in certain situations your data may be accessed by several other entities, including: PayPro Global Inc., a company with its registered office at 225 The East Mall, Suite 1117, Toronto, ON, M9B 0A9, Canada, and Neon Commerce, Inc., a Delaware corporation with its registered office at 333 Bush St, Floor 4, San Francisco, CA 94104, United States of America.

Other players and users Interacting with others is a huge part of our games, so they may be able to see your profile information, in-game activities, and messages you've posted.

Our Services Providers Gamesture uses vendors to help provide our Services. These vendors only use your data to provide the Services as instructed by Gamesture and for tasks like hosting, sales, player support, advertising, analytics, and fraud prevention.

Other companies and public authorities To fight fraud and illegal activity, we may need to share your data with other companies and organizations, or provide it to public authorities if they make a lawful request. We may also disclose your data if you give us permission, to comply with the law, or to protect our rights, property, or safety, as well as the rights, property, or safety of our players or others.

Advertising and Social Media Partners Our Services includes features from partners like social media tools, APIs or SDKs, and in-game advertising. These partners may access your data and follow their own privacy policies. We recommend checking out their privacy policies to learn more about their data practices.

We use the following services:


These partners may access information about your activities and device, like your IP address, mobile identifier, location, pages visited, and time of day. We may also share data we've collected about you with third-party advertising partners. This may include data (and similar data from other websites) to deliver targeted advertisements when you visit their networks. Remember, these partners follow their own privacy policies, so be sure to check them out. This type of advertising is called "interest-based advertising" or "online behavioral advertising".
Your rights You have certain rights with regards to your personal data collected by Gamesture.

You have the right to:

  • Access your personal data held by Gamesture free of charge in most circumstances.
  • Rectify any inaccurate or incomplete personal data by changing it yourself or contacting Gamesture.
  • Obtain deletion of your personal data in many cases by simply requesting it through the contact information provided. Note that deletion may be permanent and your data cannot be recovered. Alternatively, you may delete the personal data associated with your account by deleting your account directly within Gamesture's applications or games. To delete your account, navigate to the account settings in the relevant application or game and select the "delete account" option.
  • The right to object: If your personal data is being processed based on legitimate interests or consent, you have the right to object to this processing. If you do, the processing will stop unless there are compelling and prevailing reasons to continue.
  • The right to file a complaint: If you have concerns about how your personal data is being processed, you have the right to file a complaint with the appropriate authority.
  • The right to restriction of processing: You can ask for restrictions on how your personal data is being processed.
  • The right to personal data portability: You have the right to receive your personal data in a format that can be easily transferred to another entity.

In cases where the processing of data takes place on the basis of the consent granted, you have the right to withdraw the granted consents at any time but without affecting the lawfulness of processing before their withdrawal. You can withdraw your consent by sending a message to the following address: Gamesture sp. z o.o, ul. Grodziska 8, 60-363 Poznan Poland, or the e-mail address: privacy@gamesture.com.
In cases you believe that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with the supervisory body, i.e. the President of the Personal Data Protection Office based in Warsaw. Details on submitting complaints can be found on the UODO website at: uodo.gov.pl/en.

Say goodbye to promotional emails and direct marketing You can opt out of promotional emails and other marketing communications from us by following the instructions in the emails or changing your in-game settings. Please note that it may take a little time for the changes to take effect. You may still receive non-promotional communications from us, like updates to our Terms of Services or Privacy Policy. With your permission, we may use your data for additional purposes, such as showing you local events based on your GPS location.

Push Notifications We may send you notifications through our mobile apps. If you do not wish to receive these notifications, you can turn them off at any time by adjusting the settings on your mobile device.

Opt-out of targeted advertising You have the option to stop receiving interest-based ads on our mobile apps by checking the privacy settings on your Android or iOS device and selecting "Limit Ad Tracking" (for Apple iOS) or "Opt-out of Interest Based Ads" (for Android)
How do we protect your data
Security Safeguards To guarantee a secure gaming experience, we are constantly working on enhancing our security measures. This includes administrative, technical, and physical security measures to protect your information from unauthorized access, loss, misuse, or alteration. We have also teamed up with Grey Wizard, a company that provides comprehensive protection against cyberattacks and DDoS threats. Their combination of expert knowledge and artificial intelligence allows for prompt detection and response to all types of threats, ensuring the safety of your data.
How long we process your data Your data is kept by us as long as your account is active or as required to deliver the Services to you. From time to time, we may remove inactive game accounts and periodically review and discard any unnecessary data. However, if you request us to erase your personal information, we may still retain some of it for valid business reasons, such as fulfilling legal obligations, settling disputes, and upholding our agreements.
Children Gamesture follows all relevant privacy laws and regulations regarding children and the internet, including those applicable to residents of the European Economic Area and the United States. Our collection of personal information is restricted to the internal workings of the game. In the event that we unintentionally gather personal data from a child under 13 years of age, which goes beyond what is legally permitted, we will immediately remove that data. If you are a parent or guardian of a child under the age of 13 or under the age of legal consent in your area and believe they have provided Gamesture with personal information without your permission, please reach out to us at privacy@gamesture.com.
Cookies and similar technologies Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyze use, target advertisements and prevent fraud. Cookies and similar technologies allow us and our partners to store their preferences and track your activities within the Services. Note that our partners may operate under their own privacy policies.
We and our partners collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. We do so in order to:
  • detect and prevent fraud;
  • allow users to use the Services on one device and pick up seamlessly where they left off on another device;
  • analytics, personalization and attribution;
  • limit the number of times a user is shown the same advertisement, across all known or inferred devices; and/or;
  • provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.

Managing cookie settings Service cookies that are necessary to use the website are automatically installed on the User's device. Their use is necessary to provide a telecommunications service (data transmission to display the content). The user cannot opt out of these cookies if he or she wants to use the website.
The user may consent to the installation of functional cookies by clicking the "Accept All Cookies" button on the banner that appears after entering the website. Then we will be entitled to install functional cookies in accordance with the settings of the browser used by the User (in the case of default settings, all cookies are installed).
The user may consent to the installation of only selected functional cookies. To do this, just click the "Cookies Settings" button on the banner that appears after entering the website and select the cookies for the installation of which the User wants to consent.
The user may withdraw the consent granted at any time. For this purpose, the User should click on the icon in the lower left corner and select the withdrawal of consent.

Withdrawal of consent to the usage of cookies is also possible through the browser settings. Detailed information on this can be found at the following links:

In the absence of consent or in the event of withdrawal of consent for a given type and provider of cookies (if the installation of cookies is not accepted in accordance with the browser settings), Gamesture does not install such cookies on the User's end device.
The user may at any time verify the status of his current privacy settings for the browser used using the tools available at the following links:
Updates Gamesture has the right to change its Privacy Policy at any time without prior notice. The updated version will be posted on the company's website and if there are any significant changes, a notification will be given. By continuing to use the Services, you are agreeing to the updates. The updates will become effective 30 days after they are posted on the website, unless stated otherwise by Gamesture.