Privacy Policy and Cookies

Hello!

If you’ve found yourself here, it’s a sure sign that you value your privacy. We fully understand this, which is why we’re giving you this document — in one place you’ll find the rules on how personal data is processed and how cookies and other tracking technologies are used in connection with the operation of the website https://bettergaming.pro.

A quick formal note to begin with – the administrator of the website is Better Gaming Agency sp. z o. o., based in Warsaw, al. Rzeczypospolitej 20/137, 02-972, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number: 0000861416, NIP (Tax ID): 9512453809, with a share capital of PLN 5,000.

This privacy policy has been structured in a Q&A format. We chose this form to ensure clarity and transparency of the information presented to you. Below you’ll find the table of contents, which corresponds to the questions we answer in the following sections:

1.    Who is the administrator of personal data?

2.    Who can you contact regarding personal data?

3.    What information about you do we hold?

4.    Where do we obtain your personal data from?

5.    Is your data secure?

6.    For what purposes do we process your personal data?

7.    How long will we store your personal data?

8.    Who are the recipients of your personal data?

9.    Do we transfer your data to third countries?

10. Do we use profiling?

11. What rights do you have regarding data processing?

12. Do we use cookies and what exactly are they?

13. On what basis do we use cookies?

14. Can you disable cookies?

15. For what purposes do we use our own cookies?

16. What third-party cookies are used?

17. Do we track your behavior on the website?

18. Do we target ads at you?

19. How can you manage your privacy?

20. What are server logs?

21. Is there anything else you should know?

22. Can this privacy policy be changed?

If you have any doubts regarding this privacy policy, you can always contact me by sending an email to iod@bettergaming.pro.

1: Who is the administrator of your personal data?

The administrator of your personal data is Better Gaming Agency sp. z o. o., based in Warsaw, al. Rzeczypospolitej 20/137, 02-972, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number: 0000861416, NIP (Tax ID): 9512453809, with a share capital of PLN 5,000.

2: Who can you contact regarding the processing of your personal data?

As part of implementing personal data protection in our organization, we decided not to appoint a Data Protection Officer, since in our case it is not required.
For any matters related to personal data protection and privacy in general, you can contact us at iod@bettergaming.pro.

3: What information about you do we hold?

Depending on the purpose, we may process the following information about you:

• first and last name,
• e-mail address,
• data contained in e-mail correspondence,
• approximate location.

The scope of data processed is precisely described with reference to each specific processing purpose. Details on this can be found later in this policy.

Moreover, we use tools that collect a range of information about how you use our website, in particular:

• information about your operating system and web browser,
• pages visited,
• time spent on the site,
• navigation between individual subpages,

• clicks on individual links,
• the source from which you entered the website,
• your age group,
• your gender,
• your approximate location (limited to the city),
• your interests, determined based on your online activity.

These pieces of information are referred to in this privacy policy as “Anonymous Information.”

In our view, Anonymous Information by itself does not constitute personal data, since it does not allow us to identify you, and we do not combine it with the typical personal data we collect about you. Nevertheless, considering the strict case law of the Court of Justice of the European Union and the divided opinions among legal experts, as a precaution, in case Anonymous Information were to be classified as personal data, we have also included detailed explanations regarding the processing of such information in this privacy policy.

Since Anonymous Information is collected by external tools we use (these tools are discussed later in this privacy policy), such information is also processed by the providers of these tools according to the terms of their regulations and privacy policies.

Anonymous Information is also used by the providers of these tools to deliver and improve their services, manage them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize the content and ads displayed across their services, websites, and applications.

4: Where do we obtain your personal data from?

In most cases, you provide it yourself. This happens when, for example:

• you contact us via a form or by e-mail.

In addition, some information about you may be collected automatically through the tools we use:

• the website’s mechanism collects your IP address, which is anonymized after being gathered,
• external tools using cookies (described later in this privacy policy) collect Anonymous Information related to your activities on the website.

5: Is your data secure?

We care about the security of your personal data. We have analyzed the risks associated with the various processes of processing your data, and then implemented appropriate security and personal data protection measures. We continuously monitor the state of technical infrastructure, train our staff, review the procedures in place, and introduce necessary improvements.

If you have any questions regarding your personal data, we are available at iod@bettergaming.pro.

6: For what purposes do we process your personal data?

There is more than one purpose. Below is the list, followed by a more detailed explanation. Each purpose is also accompanied by the relevant legal basis for processing (under GDPR):

• sending newsletters and commercial information (for individuals subscribed to the newsletter) – Art. 6(1)(f) GDPR,
• handling correspondence – Art. 6(1)(f) GDPR,
• analytics and statistics using only Anonymous Information – Art. 6(1)(f) GDPR,
• own marketing using only Anonymous Information – Art. 6(1)(f) GDPR,
• ensuring the functionality of the YouTube player and social media plugins using only Anonymous Information – Art. 6(1)(f) GDPR.

Handling correspondence – details

When you contact us via the form or by e-mail, you naturally provide your personal data contained in the content of the correspondence, in particular your e-mail address and name. Providing this data is voluntary but necessary in order to establish contact.

In this case, your data is processed for the purpose of communicating with you, and the legal basis for processing is Art. 6(1)(f) GDPR, i.e., our legitimate interest. The legal basis for processing after the communication has ended is also our legitimate interest in archiving correspondence to ensure the ability to demonstrate certain facts in the future (Art. 6(1)(f) GDPR).

The content of correspondence may be archived, and we are not able to precisely determine when it will be deleted. You have the right to request access to the history of correspondence that you have exchanged with us (if it was archived), as well as request its deletion, unless its archiving is justified due to overriding interests, e.g., defense against potential claims from your side.

Analytics and statistics – details

We conduct analytical and statistical activities using the tools described in detail later in this privacy policy. Within these analytics tools, we only have access to Anonymous Information.

As mentioned earlier, in our opinion Anonymous Information by itself does not constitute personal data, since it does not allow us to identify you, and we do not combine it with the typical personal data we collect about you. Nevertheless, considering the strict case law of the Court of Justice of the European Union and the divided opinions among legal experts, as a precaution, in case Anonymous Information were to be classified as personal data, we have also included detailed explanations regarding the processing of such information in this privacy policy.

The processing of Anonymous Information is based on our legitimate interest, as referred to in Art. 6(1)(f) GDPR. This legitimate interest consists in creating, reviewing, and analyzing statistics related to user activity on the website in order to draw conclusions that enable subsequent optimization of the website.

We are not able to provide you with access to Anonymous Information about you, because none of this information can be assigned to any specific user. From the level of external tools, we only have insight into sets of aggregated statistics and data that are not linked to individuals.

You may, however, object to the processing of Anonymous Information about you by disabling external tools’ cookies in the cookie settings, which can be accessed via the relevant link in the footer of the site.

Own marketing – details

We carry out marketing activities using external tools, which are described in detail later in this privacy policy. Within these marketing tools, we only have access to Anonymous Information.

As mentioned earlier, in our opinion Anonymous Information by itself does not constitute personal data, since it does not allow us to identify you, and we do not combine it with the typical personal data we collect about you.

Nevertheless, considering the strict case law of the Court of Justice of the European Union and the divided opinions among legal experts, as a precaution, in case Anonymous Information were to be classified as personal data, we have also included detailed explanations regarding the processing of such information in this privacy policy.

The processing of Anonymous Information is based on our legitimate interest, as referred to in Art. 6(1)(f) GDPR. This legitimate interest consists in creating Custom Audiences based on Anonymous Information and targeting ads using Anonymous Information, which falls within the scope of marketing our own products and services.

We are not able to provide you with access to Anonymous Information about you, because none of this information can be assigned to any specific user. From the level of external tools, we only have insight into sets of aggregated statistics and data that are not linked to individuals.

You may, however, object to the processing of Anonymous Information about you by disabling external tools’ cookies in the cookie settings, which can be accessed via the relevant link in the footer of the site.

Additional tools – details

We use Google Analytics and Facebook Pixel (FB) on our website, which process Anonymous Information.

As mentioned earlier, in our opinion Anonymous Information by itself does not constitute personal data, since it does not allow us to identify you, and we do not combine it with the typical personal data we collect about you. Nevertheless, considering the strict case law of the Court of Justice of the European Union and the divided opinions among legal experts, as a precaution, in case Anonymous Information were to be classified as personal data, we have also included detailed explanations regarding the processing of such information in this privacy policy.

The processing of Anonymous Information is based on our legitimate interest, as referred to in Art. 6(1)(f) GDPR. This legitimate interest, in this case, consists in ensuring the possibility of using additional functionalities on the website.

We are not able to provide you with access to Anonymous Information about you, because none of this information can be assigned to any specific user. From the level of external tools, we only have insight into sets of aggregated statistics and data that are not linked to individuals.

You may, however, object to the processing of Anonymous Information about you by disabling external tools’ cookies in the cookie settings, which can be accessed via the relevant link in the footer of the site.

7: How long will we store your personal data?

The retention periods for data have been indicated separately for each processing purpose. You will find this information within the detailed sections dedicated to each purpose of processing. Most data is deleted after the expiration of the limitation period for potential claims.

8: Who are the recipients of your personal data?

We dare say that modern business cannot function without the services provided by third parties — and we also use such services. Some of these services involve the processing of your personal data. The external service providers involved in processing your personal data include:

• a hosting provider, who stores data on the server,
• a cloud service provider, where files that may contain your personal data are stored,
• a technical support provider, who gains access to the data if technical work concerns areas where personal data is located,
• other subcontractors, who gain access to the data if the scope of their work requires such access.

All of the entities listed above process your data on the basis of data processing agreements and guarantee an appropriate level of personal data protection.

If necessary, your data may also be shared with a legal adviser or attorney bound by professional secrecy. Such a necessity may arise from the need to obtain legal assistance that requires access to your personal data.

Your personal data may also be transferred to tax authorities to the extent necessary to fulfill tax, accounting, and reporting obligations. This particularly concerns any declarations, reports, statements, and other accounting documents in which your personal data may appear.

In addition, if necessary, your personal data may be shared with entities, bodies, or institutions authorized to access data under the law, such as the police, security services, courts, or prosecutors’ offices.

Furthermore, when it comes to Anonymous Information, access to such data is granted to providers of the tools or plugins that collect Anonymous Information. These providers act as independent administrators of the data they collect and may share that data under the rules set out in their own terms of service and privacy policies, over which we have no control.

9: Do we transfer your data to third countries or international organizations?

No, your personal data is not transferred to third countries.

However, we remind you here once again that we use external tools that may collect Anonymous Information. We have mentioned this several times in this privacy policy, including in response to the previous question. The providers of these tools often use servers located all around the world to store the information they collect — in particular, in the United States of America (USA).

If you have subscribed to our newsletter, your personal data may also be shared with entities authorized under the law or with entities to whom we have entrusted activities related to newsletter distribution, in particular:

• MailerLite Limited, a company registered in Ireland at 38 Mount Street Upper, Dublin 2, D02 PR89, Ireland.

10: Do we use profiling? Do we make automated decisions based on your personal data?

We do not make decisions about you that are based solely on automated processing, including profiling, which would produce legal effects concerning you or similarly significantly affect you.

Yes, we do use tools that may perform certain actions depending on information collected through tracking mechanisms, but we believe these actions do not significantly affect you. They do not differentiate your situation as a customer, do not affect the terms of any contract you could enter into, etc.

We emphasize that within the tools we use, we only have access to Anonymous Information. This information is stored on the servers of the respective tool providers, and those servers are often located around the world.

11: What rights do you have regarding the processing of your personal data?

Under the GDPR, you may have the following rights related to the processing of your personal data:

• Right of access – you have the right to access your data and obtain a copy of it,
• Right to rectification – you can request correction of your data,
• Right to erasure – if you believe there is no basis for your data to be processed, you can request that it be deleted,
• Right to restriction of processing – you can request that processing be limited only to storage or agreed actions if, in your opinion, we have incorrect data or are processing it without justification,
• Right to object – you can object to processing based on legitimate interest; you should indicate your particular situation which you believe justifies stopping the processing covered by the objection. We will then stop processing your data for these purposes, unless we demonstrate that there are compelling legitimate grounds for the processing which override your rights, or that the data is necessary for establishing, pursuing, or defending legal claims,
• Right to data portability – you have the right to receive, in a structured, commonly used, machine-readable format, the personal data you provided on the basis of a contract or your consent; you may also request that this data be transferred directly to another entity,
• Right to withdraw consent – if you previously gave your consent to the processing of personal data, you may withdraw it at any time,
• Right to lodge a complaint with a supervisory authority – if you believe that we are processing your data unlawfully, you may file a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) or another competent supervisory authority.

The rules related to exercising the rights mentioned above are described in detail in Articles 16–21 of the GDPR. We encourage you to read those provisions. From our side, we believe it is necessary to explain that the above-mentioned rights are not absolute and will not apply to all processing activities of your personal data.

We emphasize, however, that one of the rights listed above always applies: if you believe that the processing of your personal data has violated data protection regulations, you may lodge a complaint with the supervisory authority (the President of the Personal Data Protection Office).

You can also always request information about what data we hold about you and for what purposes we process it. Simply send an email to iod@bettergaming.pro. We have made every effort to ensure that the information you are interested in is presented comprehensively in this privacy policy. The email address provided above can also be used if you have any questions related to the processing of your personal data.

12: Do we use cookies and what exactly are they?

Our website, like almost all other websites, uses cookies.

Cookies are small text files stored on your end device (e.g., computer, tablet, smartphone), which can be read by our IT system (first-party cookies) or by third-party IT systems (third-party cookies). Certain information may be recorded and stored in cookies, which IT systems can then access for specific purposes.

Some of the cookies we use are deleted after the end of your browser session, i.e., once you close it (session cookies). Other cookies remain stored on your end device and allow your browser to be recognized when you return to the site (persistent cookies).

If you would like to learn more about cookies in general, you can, for example, read this resource. (https://pl.wikipedia.org/wiki/HTTP_cookie)

13: On what basis do we use cookies?

We use cookies on the basis of your consent, except in cases where cookies are necessary for the proper provision of electronic services to you.

Cookies that are not essential for the proper provision of electronic services remain blocked until you give your consent to their use. During your first visit to the site, we display a message asking for your consent, along with an option to manage cookies — i.e., to decide which cookies you agree to and which you want to block.

Please note that disabling or limiting cookies may prevent you from using some of the functions available on the website and may cause difficulties in using the site, as well as many other websites that use cookies. For example, if you block cookies from social media plugins, buttons, widgets, and social features implemented on the site may be unavailable to you.

14: Can you disable cookies?

Yes, you can manage cookie settings in your web browser. You can block all or selected cookies. You can also block cookies from specific websites. At any time, you may also delete previously saved cookies and other site and plugin data.

Web browsers also offer the option of using incognito mode. You can use this if you don’t want information about visited sites and downloaded files to be saved in your browsing and download history. Cookies created in incognito mode are deleted once all incognito windows are closed.

There are also browser plugins that allow you to control cookies, such as Ghostery. Control options over cookies may also be provided by additional software, particularly antivirus packages, etc.

In addition, there are online tools that allow you to control certain types of cookies, especially to collectively manage behavioral advertising settings.

We also give you the option to control cookies directly from our website. We have implemented a special cookie management mechanism that allows you to block those cookies you do not wish to accept.

Please note that disabling or limiting cookies may prevent you from using some of the features available on the website and may cause difficulties in using the site, as well as many other websites that use cookies. For example, if you block cookies from social media plugins, the buttons, widgets, and social features implemented on our website may be unavailable to you.

15: For what purposes do we use our own cookies?

Our own cookies are used to ensure the proper functioning of specific website mechanisms, such as testing the site’s responsiveness, proper submission of forms available on the website, etc.

Our own cookies also store information about the cookie settings you defined via the cookie management mechanism.

16: What third-party cookies are used?

The following third-party cookies are used on our website:

• Google Analytics,
• Google Ads,
• Facebook Ads.

Details regarding each third-party cookie are described below.

Google Analytics – details

We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Our activities in this area are carried out on the basis of our legitimate interest, which consists in creating statistics and analyzing them in order to optimize the website.

To use Google Analytics, a special Google Analytics tracking code has been implemented in the site’s code. The tracking code uses cookies from Google LLC related to the Google Analytics service.

You can block the Google Analytics tracking code at any time by installing a browser add-on provided by Google.

Google Analytics automatically collects information about your use of the website. The information collected in this way is usually transmitted to Google servers, which may be located worldwide, and stored there.

Due to IP anonymization being activated, your IP address is shortened before being transmitted further. Only in exceptional cases is the full IP address sent to Google servers and shortened there. The anonymized IP address transmitted by your browser within Google Analytics is generally not combined with other data held by Google.

We emphasize that within Google Analytics we only have access to Anonymous Information.

The Google Analytics and Google Analytics 360 services have been certified under the independent ISO 27001 security standard. ISO 27001 is one of the most widely recognized standards in the world and confirms that the systems supporting Google Analytics and Google Analytics 360 meet appropriate requirements.

If you are interested in details on how Google uses data from sites and applications that use Google services, we encourage you to review this information.

Google Ads – details

We use the remarketing functions available within the Google AdWords system, operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Our activities in this regard are based on our legitimate interest, which is marketing our own products and services.

When you visit our website, a Google remarketing cookie file is automatically placed on your device, which collects information about your activity on the site. Thanks to the information gathered in this way, we can display ads to you within the Google network based on your behavior on the website.

For example, if you view a product, that fact will be recorded by the remarketing cookie, which will allow us to target you with an ad related to that product or any other ad we deem relevant. This ad will then be displayed to you within the Google network while you browse the Internet, visit other websites, etc.

We emphasize that when using Google Ads, we only use Anonymous Information.

When using Google AdWords, we are only able to define audience groups that we would like our ads to reach. Based on this, Google decides when and how to present an ad to you.

Further processing of information takes place only if you have consented to Google combining your browsing history with your account and using information from your Google account to personalize ads displayed on websites. In such a case, Google will use your data to create and define lists of target groups for remarketing across different devices. To this end, Google temporarily combines collected information with other data it holds in order to create target groups.

If you do not wish to receive personalized ads, you can manage your ad settings directly on Google: https://adssettings.google.com/.

If you are interested in details on how Google uses data from websites and apps that use Google services, please review this information: https://policies.google.com/technologies/partner-sites.

Facebook Ads – details

We use the marketing functions available within the Facebook Pixel system, operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland. Our activities in this regard are based on our legitimate interest, which is marketing our own products and services.

When you visit our website, a Meta remarketing cookie is automatically placed on your device, which collects information about your activity on the site. Thanks to the information gathered in this way, we can display ads to you within Meta products depending on your behavior on the website.

For example, if you view a product, that fact will be recorded by the remarketing cookie, which will allow us to target you with an ad related to that product or any other ad we consider relevant. This ad will then be displayed to you within Meta products while you use the Internet, browse other websites, etc.

We emphasize that when using Facebook Pixel, we only use Anonymous Information.

When using Facebook Pixel, we are only able to define audience groups that we would like our ads to reach. Based on this, Meta decides when and how to present an ad to you.

Further processing of information takes place only if you have consented to Meta combining your browsing history with your account and using information from your Facebook or Instagram account to personalize ads displayed on websites. In such a case, Meta will use your data to create and define lists of target groups for remarketing across different devices. To this end, Meta temporarily combines collected information with other data it holds in order to create target groups.

If you do not wish to receive personalized ads, you can manage your ad settings directly on Facebook: https://www.facebook.com/adpreferences/.

If you are interested in details on how Meta uses data from websites and applications that use Meta services, please review this information:  https://www.facebook.com/business/m/privacy-and-data.

17: Do we track your behavior on our website?

Yes, we use Google Analytics, Google AdWords, and Facebook Pixel, which involve collecting information about your activity on our website. These tools have been described in detail in the section dedicated to third-party cookies, so we will not repeat that information here.

18: Do we target ads at you?

Yes, we use Facebook Ads and Google Ads, through which we can target ads to specific audience groups defined on the basis of various criteria such as age, gender, interests, occupation, job, or previous activities undertaken on our website. These tools have been described in detail in the section dedicated to third-party cookies, so we will not repeat that information here either.

19: How can you manage your privacy?

The answer to this question can be found in many parts of this privacy policy when describing specific tools, behavioral advertising, cookie consent, etc. Nevertheless, for your convenience, we have gathered this information in one place. Below you will find a list of options for managing your privacy:

• cookie settings in your web browser,
• browser plugins that support cookie management, e.g., Ghostery,
• additional software for managing cookies,
• incognito mode in your web browser,
• behavioral advertising settings, e.g., youronlinechoices.com,
• the cookie management mechanism available directly on our website,
• Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout,
• Google Ads Settings: https://adssettings.google.com/,
• Facebook Ads Settings: https://www.facebook.com/ads/settings.

20: What are server logs?

Using the website involves sending requests to the server on which the website is stored. Each request sent to the server is saved in the server logs.

The logs include, among other things, your IP address, the server date and time, and information about the browser and operating system you are using. The logs are recorded and stored on the server.

The data stored in the server logs is not associated with specific individuals using the website and is not used to identify you.

The server logs constitute only auxiliary material used for website administration, and their contents are not disclosed to anyone except persons authorized to administer the server.

21: Is there anything else you should know?

As you can see, the subject of personal data processing, the use of cookies, and privacy management in general is quite complex. We have made every effort to ensure that this document provides you with as much knowledge as possible on issues that are important to you.

If anything is unclear to you, if you would like to learn more, or simply wish to discuss your privacy, please write to us at iod@bettergaming.pro.

22: Can this Privacy Policy be changed?

Yes. We may update or modify this Privacy Policy from time to time, in particular to reflect technological developments, changes in the law, or our internal practices.

If you are a registered user, we will notify you of any material changes to this Privacy Policy. In addition, all archived versions of the Privacy Policy will remain accessible through the links provided below.