Privacy Policy

Last update: April 5, 2024

Introduction

We appreciate that you are aware of and care about your own personal privacy interests, and we take it seriously. This Privacy Policy describes the PEOPLE CAN FLY Group policies and practices regarding the collection and use of your personal data and sets out your privacy rights.

This Privacy Policy has been prepared in accordance with the provisions of law, including the Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (General Data Protection Regulation) (GDPR). The PEOPLE CAN FLY Group companies located in the United Kingdom or Québec (Canada) also comply with local privacy regulations if they are more restrictive than the GDPR rules.

We recognize that information privacy is an ongoing responsibility, and we will from time to time update this Privacy Policy as we implement new personal data protection practices or adopt new privacy policies in future but also when we need to reflect legal changes. If we do so, we will make the revised Privacy Policy available online together with the date of its last update.

In what situations do we process your personal data?

We may process your personal data in the following situations:

1. You are an existing or potential client, supplier or vendor of the PEOPLE CAN FLY Group, or an employee of any of them;
2. You apply to any of PEOPLE CAN FLY Group companies in one of recruitment processes published on our website or via social media;
3. You visit our websites;
4. You have linked your profile or otherwise interacted with the PEOPLE CAN FLY Group profiles on social media;
5. You participate in an event or meeting organized by the PEOPLE CAN FLY Group;
6. You use and play games, test games, or participate in other initiatives related to the research, evaluation, development or promotion of games, developed or published by the PEOPLE CAN FLY Group;
7. You have agreed to receive our newsletter or any other materials and information.

If you feel that you need to further clarify the purposes of processing of your personal data – do not hesitate to contact us by sending an e-mail to: privacy@peoplecanfly.com.

Who is the controller of your personal data?

The Joint Controllers of your personal data are the following companies being members of the international PEOPLE CAN FLY Group:

1. PCF Group S.A., al. “Solidarności” 171, 00-877 Warsaw, Poland– as the Lead Controller;
2. People Can Fly UK Limited, Gateshead, Northern Design Centre, Abbot’s Hill Baltic Business Quarter, NE8 3DF Great Britain;
3. People Can Fly Canada Inc., B405 Ogilvy Avenue, Montreal, Quebec, H3N 1M3, Canada;
4. People Can Fly U.S., LLC, C/O Baker Tilly US, LLP, 205 N. Michigan Avenue, 28th Floor, Chicago, IL 60601, USA;
5. People Can Fly Chicago, LLC, C/O Baker Tilly US, LLP, 205 N. Michigan Avenue, 28th Floor, Chicago, IL 60601, US;
6. People Can Fly Ireland Limited, Regus House, Harcourt Centre, Harcourt Road, Dublin 2, Dublin, D02 HW77, Ireland.

Whom can you contact regarding the processing of your personal data?

The Lead Controller appointed Agata Klimek-Cortinovis as the Data Protection Officer. You should send any questions regarding the processing of your personal data by e-mail to: privacy@peoplecanfly.com, or by ordinary mail to: PCF Group S.A., al. „Solidarności” 171, 00-877 Warsaw, Poland.

For what purpose and on what legal basis do we process your personal data?

The scope and the purpose of processing of your personal data depends on the relationship between you and us.

If you are an existing or potential client, supplier or vendor of the PEOPLE CAN FLY Group, or an employee of any of them

We may process your personal data for the following purposes:

1. to perform a contract to which the data subject is party or to take appropriate steps at the request of the data subject prior to entering into a contract (Article 6 (1) (b) of the GDPR);
2. to ensure that the Joint Controllers comply with the legal obligations to which they are subject (Article 6 (1) (c) of the GDPR);
3. to protect legitimate interests of the Joint Controllers which include defending and exercising legal claims (Article 6 (1) (f) of the GDPR).

If you apply to any of PEOPLE CAN FLY Group companies in one of recruitment processes published on our website or via social media

We may process all or some of the personal data listed below for the following purposes:

1. identity data, address, education, length of previous employment, employment history, contact details (telephone and e-mail), to a limited extent your image (unless you follow our guidelines and send us your resume without a picture) – for the purpose of conducting a recruitment process leading to the execution of the employment contract or an agreement other than an employment contract (Article 6 (1) (b) of the GDPR);
2. other data that you provide in the recruitment documents – based on your freely given and informed consent to their processing (Article 6 (1) (a) of the GDPR);
3. identity data, address, education, length of previous employment, employment history, contact details (telephone and e-mail), to a limited extent your image (unless you follow our guidelines and send us your resume without a picture) and other data that you provide in the recruitment documents – for the purposes of future recruitment processes;
4. identity data, address, contact details (telephone and e-mail) – in relation to the Joint Controllers’ legitimate interests which include defending and exercising legal claims (Article 6 (1) (f) of the GDPR).

If you visit our websites

We may process your personal data included in Essential Cookies (more about Cookies here: https://peoplecanfly.com/wp-content/uploads/2020/08/cookie_notice.pdf) based on Joint Controllers’ legitimate interests (Article 6 (1) (f) of the GDPR). Our legitimate interest here is to make our websites available, ensure their security and gather basic statistical data. Your data that may be collected may include: your source IP address, IP address country of origin and the http referrer (i.e. the website from which you reached our site).

We may also process your personal data in relation to giving you the opportunity to visit and use our websites (Article 6 (1) (b) of the GDPR).

We may also process your personal data in Cookies other than Essential Cookies based on your freely given and informed consent (Article 6 (1) (a) of the GDPR) that you can withdraw at any time using our Cookie Consent Kit.

If you have linked your profile or otherwise interacted with the PEOPLE CAN FLY Group profiles on social media

We may process all or some of the personal data listed below for the following purposes:

1. identity data, name of the profile on the portal, e-mail address, other user data provided by you using the privacy settings on a given portal or made available by you in any other way in connection with your activities on the PEOPLE CAN FLY Group profile – in relation to the Joint Controllers’ legitimate interests which include informing about the activities of the PEOPLE CAN FLY Group and promoting its services (Article 6 (1) (f) of the GDPR);
2. identity data, contact details – in relation to the Joint Controllers’ legitimate interests which include verifying your identity, defending and exercising legal claims insofar as it may be necessary as a result of or in connection with your activity on the PEOPLE CAN FLY Group profile on social media (Article 6 (1) (f) of the GDPR).

If you participate in an event or meeting organized by the PEOPLE CAN FLY Group

We may process all or some of the personal data listed below for the following purposes:

1. identity data, contact details (telephone and e-mail), place of work – in order to perform the agreement executed by way of your approval of the terms of participation in the event or meeting (Article 6 (1) (b) of the GDPR);
2. identity data, contact details (telephone and e-mail) – in relation to the Joint Controllers’ legitimate interests which include defending and exercising legal claims insofar as they may result from or relate to the performance of the agreement (Article 6 (1) (f) of the GDPR;
3. identity data, contact details (telephone and e-mail), place of work – – in relation to the Joint Controllers’ legitimate interests which include the performance of statistical and archive duties (Article 6 (1) (f) of the GDPR).

If you use or play games, test games, or participate in other initiatives related to the research, evaluation, development or promotion of games, developed or published by the PEOPLE CAN FLY Group

In some cases, we may process your personal data such as: name and surname, e-mail address, username, technical information about any devices you use to access our games (including IP address), operating system, type of browser or other software, information about your computer hardware and other information (including technical information) that you provide when using and playing our games. We may process this data on the basis of the Joint Controllers’ legitimate interest set out in Article 6 (1) (f) of the GDPR in order to communicate with you as a user of our games and to improve or modify our games.

If you test our games or participate in other initiatives related to the research, evaluation, development or promotion of our games, in addition to the data you provide for the purpose of using the games, we may process your personal data that you provide to us for the purpose and in connection with qualifying for the research and participation in our initiatives, e.g. name and last name, contact details, ID number, local ID number, place of leaving, gender, age, family status, bank account number (if participation in the tests involves remuneration), video and audio recordings from gameplay, chat records, and feedback provided by you. In exceptional cases and with your consent, we may process data relating to your health and ethnicity. We may process this data due to the need to conclude and perform a contract for participation in our initiatives (Article 6 (1) (b) of the GDPR). The data of people who are not qualified to participate in the initiatives are immediately deleted.

Please remember that depending on the platform on which you preorder, buy or use (including testing) our games, the platform owners may collect different data about you. More information on the processing of your personal data in this respect can be found on the relevant platforms.

If you have agreed to receive our newsletter or any other materials and information

We may process your identity data, email address and other contact data you have given us on the basis of your freely given consent (Art. 6 (1) (a) of the GDPR) for the purpose of sending you a newsletter or other materials and information you may request.

Are we going to profile your personal data, or take automatic decisions based on your personal data?

No. We have no intention to create profiles based on your personal data, or take automatic decisions based on your personal data.

Must you provide your personal data to us?

If you are an existing or potential client, supplier or vendor of the PEOPLE CAN FLY Group, or an employee of any of them

Providing your personal data is voluntary, however it is necessary in order to engage in or continue your cooperation with us.

If you apply to any of PEOPLE CAN FLY Group companies in one of recruitment processes published on our website or via social media

Providing your personal data is voluntary, however it is necessary for conducting the recruitment process in which you wish to participate. You are not obliged to provide us with the personal data that are to be given on the basis of your consent, and we are not allowed to let your decision in this respect determine the outcome of our recruitment process.

If you visit our websites

Your personal data are processed based on our legitimate interests and in relation to the provision of our services as we need them to ensure the functionality of our websites. With respect to the personal data that are to be given on the basis of your consent – providing such data is voluntary.

If you have linked your profile or otherwise interacted with the PEOPLE CAN FLY Group profiles on social media

Providing your personal data is voluntary but necessary to provide you with access to the content published on the PEOPLE CAN FLY Group’s social media profiles or to participate in events organized via the PEOPLE CAN FLY Group’s social media profiles.

If you participate in an event or meeting organized by the PEOPLE CAN FLY Group

Providing your personal data is voluntary, however it is necessary to facilitate your participation in the event or meeting in which you are willing to participate.

If you use or play games, test games, or participate in other initiatives related to the research, evaluation, development or promotion of games, developed or published by the PEOPLE CAN FLY Group

Your personal data are processed based on our legitimate interests and in relation to the provision of our services as we need them to ensure the use of our games, their development and modification as well as improvement or our services. Providing personal data processed in connection with the conclusion and performance of a contract for participation in tests or our other initiatives is necessary to conclude and perform the contract.

If you have agreed to receive our newsletter or any other materials and information

Providing your personal data is voluntary, however it is necessary to send you a newsletter or other information you may request.

What are your rights as data subject?

You have the right to:

1. access to your personal data;
2. correct your personal data;
3. withdraw your consent at any time by sending an e-mail to: privacy@peoplecanfly.com. The withdrawal of consent is binding for the Joint Controllers with regard to the data the processing of which was based on such consent. The withdrawal of consent will not affect the lawfulness of processing based on your consent before its withdrawal;
4. restrict the processing of your personal data;
5. have your personal data erased (the right to be forgotten);
6. transfer your personal data;
7. object to the processing of your personal data when it is carried out on the basis of Article 6 (1) (f) of the GDPR (i.e. based on controller’s legitimate interests).

Furthermore, you have the right to contact the relevant regulatory authorities of the European Union or its member states at any time and lodge a complaint in the event of a possible breach of data protection regulations.

How long will PEOPLE CAN FLY Group store your data?

The PEOPLE CAN FLY Group stores your personal data processed on the basis of our legitimate interests:

1. no longer than 12 months; or
2. until an objection is made – if before the lapse of the 12-month period you effectively object to the processing of your data and there are no other grounds for further processing by us; or
3. until our claims are time-barred – if they serve as the basis of our legitimate interests;
4. video monitoring data is stored no longer than the period permitted by local law.

The PEOPLE CAN FLY Group stores your personal data processed in connection with the performance of a contract or making a request prior to entering into a contract for a period which is necessary to perform the contract or satisfy the request.

The PEOPLE CAN FLY Group stores your personal data processed in connection with a legal obligation imposed on the PEOPLE CAN FLY Group by virtue of law for a period of time prescribed by that law.

The PEOPLE CAN FLY Group stores your personal data processed on the basis of your consent until you withdraw your consent to the processing.

Roles and responsibilities of the members of our personnel

Only authorized personnel, who have a business need to know, have access to your personal data. These employees have been informed of their obligations to preserve the confidentiality of your personal data. The PEOPLE CAN FLY Group applies reasonable technical, contractual, administrative and tangible measures to protect your personal data against its unauthorized use or disclosure, as well as its loss or theft, including encryption when required. Authorised employees who have access to your personal data may use it only in accordance with the principles set out in this Privacy Policy, internal regulations of the PEOPLE CAN FLY Group and applicable legislation.

Minors

The PEOPLE CAN FLY Group takes special precautions to comply with applicable law regarding minor’s privacy and does not intend to collect personal data from minors under 16 years of age without consent given by the person having parental authority or by the tutor. If you think any of the PEOPLE CAN FLY Group companies has done this, please let us know.

To whom we may disclose your data?

The PEOPLE CAN FLY Group may disclose your personal data to its service providers or vendors, e.g. IT service providers, hosting providers or marketing solutions providers. However, your personal data will always be treated as confidential and will not be disclosed to any third parties that do not act on our behalf, unless you have consented to their disclosure in writing or electronically, or unless we are not legally entitled or obliged to do so.

As an international organization we may transfer your personal data outside the European Economic Area (EEA) – to other PEOPLE CAN FLY Group companies referred to as the Joint Controllers, if it is necessary to fulfill legitimate interest of those Joint Controllers, or to our IT service or hosting providers. In such case the data transfer is secured by mutual agreements based on standard contractual clauses approved by the European Commission or other mechanisms introduced pursuant to the principles set out in the GDPR or privacy regulations in the United Kingdom or Québec (Canada).

We do not sell the personal data we process to third parties or make them available for advertising purposes.