Legal

Last updated on: 20-12-2023

Whitetower.games (from now on referred to as, «Website» or “the Website”) is a website made and managed by White Tower Games sp. z o.o. (from now on referred to as “Company” or “the Company”), a company whose legal entity is based in the Republic of Poland (PL).

This page is used to inform you of:

About the company
Our privacy policies:
- This website’s privacy policy
- Our game’s privacy policy
Our cookie policy

1. About the Company

The Company, whose complete legal name is WHITE TOWER GAMES SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, with VAT ID PL6772482189 is a Polish legal entity whose commercial activities consist of producing video games and business-related software development, systems administration, web development and I.T. related work.

White Tower Games is registered at the following address: ul. Szańcowa 44, 01-458 Warszawa, Mazowieckie, Poland.

White Tower Games is registered in the Polish State Court Register or Krajowy Rejestr Sądowy ( KRS ID 0000985532 ) with the following PKD activity types:

58, 21, Z, DZIAŁALNOŚĆ WYDAWNICZA W ZAKRESIE GIER KOMPUTEROWYCH
Publishing of computer games – Main activity
62, 01, —, DZIAŁALNOŚĆ ZWIĄZANA Z OPROGRAMOWANIEM
Computer programming activities
62, 02, —, DZIAŁALNOŚĆ ZWIĄZANA Z DO
Computer consultancy activities
63, 11, —, PRZETWARZANIE DANYCH; ZARZĄDZANIE STRONAMI INTERNETOWYMI
(HOSTING) I PODOBNA DZIAŁALNOŚĆRADZTWEM W ZAKRESIE INFORMATYKI
Data processing, hosting and related activities
63, 12, —, DZIAŁALNOŚĆ PORTALI INTERNETOWYCH
Web portals

Business contact email: contact@whitetower.games

2. Privacy Policies

This page is used to inform you of the policies referring to the collection, usage and sharing of personal and non-personal data derived from the usage of the Website and of our products.

We do not share your personal information with whomever unless specified otherwise within the following privacy policies.

2.1 Privacy Policy - Website

This privacy policy governs the use of the following website ( https://whitetower.games/ & https://www.whitetower.games/ ) and equally governs websites created by the Company for internal use and for its own products. The following is an exhaustive list of the websites in which this privacy policy is applicable :

(i) https://fiefdomgame.com/ & https://www.fiefdomgame.com/

(ii) https://casting.whitetower.games/

(iii) https://fiefdom.whitetower.games/

By using this website or any of the websites listed in this clause, you accept the collection and usage of the data that is in correlation with this privacy policy. The obtained or created data is used to ends exhaustively described in this document.

2.1.1 Definitions

Personally Identifiable Information (PII): it is a data type that when used on its own or in conjunction with other data types, can identify a specific individual or user.

Technical data: it is a data created and used by the communication medium (i.e. the web server) to establish and guarantee the communication.

Usage data: it is an anonymously generated data created by naturally interacting with the Website.

User data: data created by being a Website’s user.

2.1.2 What data do we collect ?

This is what we can obtain about you:

Personally Identifiable Information: name, surname, company name, phone number, email address, business address, business or personal ID number.

Technical data: browser’s user agent, IP address, device information, operating system type and version, browser language, browser resolution and other metadata provided by your Internet browser.

Usage data: time spent on the site, on a specific page, actions made on the site, browsed pages, entry page, exit page and other automatically collected data.

User data: form data, reviews and testimonials if any, email logs.

2.1.3 How do we collect your data ?

We obtain data about you through the following methods:

Personally identifiable information: when you fill out a form on the Website, when you contact us by email to the address contact@whitetower.games or any other address of the @whitetower.games.
Technical data: when you visit the site with any software that allows the viewing of HTTP/web data.
Usage data: when you interact with the Website, our selfhosted Matomo instance will collect usage data.
User data: when you fill out a form, send us an email or leave a testimonial/review.

2.1.4 How do we use your data ?

The personally identifiable information is used so that we may conduct our contractual relationship with you should it exist. Official document IDs are used to conduct our contractual relationship (i.e: invoicing you). Your email address is used for our back-and-forth email communication and to receive email campaigns created by the Company about the implicit service of the Website or other services administered or owned by the Company.

The technical data collected is used to establish a connection with the Website which allows you to view and interact with it. Without this information, it is technically impossible to deliver to you the content of the Website.

The usage data is analytical data, that after having gone through an anonymization process, is used internally within the Company to gain an understanding of the usage of the Company’s websites and perform changes accordingly through the analysis of certain data points. For example, this data allows us to gather the average reading time of a specific page.

Your user data is used for the treatment of your commercial or non-commercial requests and for the publishing (if a testimonial system is in place) of your testimonial or review.

Your data (PII, technical, usage, user data and/or other data) is never sold, rented, or exchanged to third parties for goods, securities, services or currency.

Please note that White Tower Games sp. z o.o. is not the only moral or physical person that interacts with data created through the interaction with the Website. Your Internet Service provider, your browser, your operating system and other programs on your device may collect their own data as a result of this same usage, and such use is outside of the scope of this privacy policy and is under their own policy.

We are subject by the laws of the Republic of Poland to collaborate with the authorities should we receive a valid court order from a Polish court.

2.1.5 How we store your data & data retention

The personally identifiable information is stored in a secure database exclusive to the Website and entirely owned and managed by the Company, and temporarily stored in the email address that is relevant to the Website.

The technical data is stored in the temporary logs of our webserver. This data is deleted after a maximum of 24 hours after your visit.

The usage data is stored in our self-hosted Matomo instance, entirely managed by the Company. This data is stored indefinitely.

The user data is stored in the Website’s secure database and temporarily in the Website’s relevant email address. This data is stored indefinitely.

The connection to the Website and to our Matomo install is secured by TLS encryption (version 1.2+) with a security rated A by the reference in the field, SSLLabs. [1] [2]

We will retain data for as long as we have a contractual relationship with you (the “data subject”) and/or for as long as we have a legitimate business interest in the data, except if the data subject has given their opt-out consent or not given an opt-in consent, depending on the type of data processed.

As a Polish legal entity we are bound by the data retention laws of the Republic of Poland. These include but aren’t limited to:

employee documentation for ten to 50 years (depending on the particular circumstances);
tax documentation for five years from the end of the calendar year in which tax payment was due.

Your personal rights as a data subject do not override the Republic of Poland’s laws in matters of data retention.

2.1.6 Email communication

When you submit your email to us, it is possible that you may receive emails from us. The content of these campaigns has been entirely made by the Company and the mentioned services or products are entirely owned or managed by the Company.

The nature of our email contents is divided into the following categories:

Marketing emails: if you are in a commercial relationship with us, it is possible that you may receive email campaigns as advertisements and/or descriptions of our services or products.
You can unsubscribe from these email campaigns at anytime by following a link labeled “Unsubscribe” which is located in the footer of each of our transactional and/or automated email correspondence.
Transactional emails: these are automated emails in relation to processes or other procedures implemented in our Website or our products. These include but aren’t limited to: password resets, registration confirmations.
Direct emails: these are emails personally written by us to you directly and may or may not be part of a commercial relationship.

2.1.7 What are your rights ?

As an individual you have the following rights:

Right to be informed: you have the right to be informed exhaustively about how your data is used.

Right to access: you have the right to access the data you have provided us through your interactions with the Company or Website.

Right to rectify: you have the right to modify, rectify the data that we have about you – such as updating the email address we have associated with your file.

Right to erasure: you have the right to have personal data and, whenever possible, all other data types we have about you, unless we have a legal need for this data.

Right to restrict processing: you have the right to restrict the processing of your personal data, under certain circumstances.

Right to oppose: you have the right to object to our processing of your personal data.

Right to data portability: you have the right to request in a machine-readable format the entirety of the personal, and whenever possible all other data types, data we have about you.

To know in which circumstances your rights apply, please check out the following link: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons 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)

2.1.8 How do I exercise my rights ?

To exercise your rights, please redact an email to the following email address privacy@whitetower.games with the subject “GDPR rights” and describe your demands.

When requesting your right to erasure, we will also delete our last email communication. Please note that the right to erasure does not override our fiscal requirements to hold certain data as per Polish law.

You may exert here your right to oppose to the collection and usage of usage data by checking the box below this paragraph. This requires your browser to allow the Website to create a cookie to save your opt-out setting.

2.1.9 Business transfer

In the events of a corporate merger, sale of the company, bankruptcy or other major disruptive corporate events our databases and other log files would be included as part of the corporate deal. Your data would then be legally owned by a new entity.

Before the realization of such an event we will attempt to contact all of the affected parties at least thirty (30) days before the completion of such occurrence.

2.2. Privacy Policy - Videogames

By playing one of our games, you accept the collection and usage of the data that is in correlation with this privacy policy as well as other third parties. The obtained or created data is used to ends exhaustively described in this document.

In order to use our games, a Steam account is mandatory. The privacy policy in regards to a Steam account and its associated data can be accessed here.

As developers of multiplayer games, our products create connections towards services comprised within the Steamworks API. The data we can access from this API is the following (extract of Steam’s privacy policy):

5.5 We make certain data related to your Steam User Account available to other players and our partners through the Steamworks API. This information can be accessed by anyone by querying your Steam ID. At a minimum, the public persona name you have chosen to represent you on Steam and your Avatar picture are accessible this way, as well as whether you have received a ban for cheating in a multiplayer game. The accessibility of any additional info about you can be controlled through your Steam Community user profile page; data publicly available on your profile page can be accessed automatically through the Steamworks API. In addition to the publicly available information, game developers and publishers have access to certain information from the Steamworks API directly relating to the users of the games they operate. This information includes as a minimum your ownership of the game in question. Depending on which Steamworks services are implemented in the game it may also include leaderboard information, your progress in the game, achievements you have completed, your multiplayer game matchmaking information, in-game items and other information needed to operate the game and provide support for it. For more information on what Steamworks services a specific game has implemented, please review its store page. While we do not knowingly share Personally Identifying Information about you through the Steamworks API such as your real name or your email address, any information you share about yourself on your public Steam Profile can be accessed through the Steamworks API, including information that may make you identifiable.

3. Cookie policy

3.1 Definition of cookie

A cookie is a file that contains a small quantity of text data sent by an HTTP server to your HTTP client (your browser), whose content is sent to the server whenever you connect to the Website.

3.2 What cookies do we use ?

Name of the cookie	Description	Expiration
PHPSESSID	Global cookie generated by all PHP environments.	When the browser is closed
MATOMO_SESSID	Generated by the connection with our Matomo install	When the browser is closed
_PK_ID	Stores the unique visitor ID	13 months
_PK_REF	Stores attributes granted by Matomo	6 months
_PK_CVAR	Stores session data	30 minutes
_PK_HSR	Stores session data and hotspot data.	30 minutes
_PK_SES	Stores session data	30 minutes
_PK_TESTCOOKIE	Determines if your browser can store cookies	Instantaneous
MATOMO_IGNORE	Stores the opt-out from Matomo’s data collection	Doesn’t expire
MTM_CONSENT	(Also defined as MTM_CONSENT_REMOVED) Stores the opt-in or opt-out from Matomo’s data collecting activities	30 years
MTM_COOKIE_CONSENT	Stores the user’s consent regarding cookie usage	30 years

3.3 How do I manage my cookies ?

Depending on the browser you use, managing cookies is done differently.

Here is a non-exhaustive list of browsers and how to access their cookie management interface.

4. Third party content

Our Website or our Products may include third party content and/or links to third party content. This content is not managed or owned by us and is thus outside the scope of this privacy policy. It is recommended that you verify the statements and nature of the third party’s privacy policy before submitting any personal data.

5. Changes to this policy

We reserve the right to modify this privacy and cookie policy without previous notice. This page serves as the unique and exclusive privacy and cookie policy of the Website.

The page displays its last modified data at the beginning of the page.

6. How to reach out to us

If you have any questions about the privacy or cookie policy of the Company or Website, the data we have about you, or for any other inquiry, don’t hesitate to contact us.

Email address: privacy@whitetower.games

Legal

Last updated on: 20-12-2023

1. About the Company

2. Privacy Policies