Privacy Policy

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This privacy policy document (hereinafter the „Privacy Policy”) determines terms and conditions on which Duality S.A. (hereinafter, “Duality”) with registered office at 00-810 Warszawa, ul. Srebrna 16 lok. 308D, Poland, registered under number of the National Court Register 0000713329, corporate number Tax Identification Number: 5252736370 may collect and process data (including personal data) concerning the users (“the User”) of this website and/or any services (e.g. communication, customer services, technical support, business inquiries) (hereinafter the “Services”). 

  1. Personal Data 

Personal data is defined as any information related to an identified (or identifiable) natural person using the Services provided by Duality (e.g. name/surname, e-mail address) (hereinafter the “Personal Data”). Duality ensures the highest standards regarding protection of personal data and confidential information, including those which results from European General Data Protection Regulation (GDPR). The Personal Data of persons under the age of 16 are especially protected, which means its collection may require obtaining consent of statutory agent (e.g. parent, legal guardian). After receiving information about collecting Personal Data of the User under age of 16, Duality will take necessary actions regarding such proccess (e.g. request consent of statutory agent). 

  1. Basis for collecting and processing Personal Data

Use of Services provided by Duality may require obtaining given Personal Data by Duality, without which the User may not be allowed to use such Services. Collecting Personal Data by Duality is made solely as a necessity for provision of such Services. Collecting Personal Data for other services (e.g. marketing, newsletter) is made only upon separate consent of the User. Duality collects Data only for justified purposes, according to the “minimalism” rules. Processing of Personal Data by Duality is based upon legal regulations binding on the territory of European Union or Member State Law.  

Collecting and processing Personal Data by Duality include the following reasons and basis: (i) the consent to the processing of his/her Personal Data given by User for one or more specific purposes, (ii) the necessity for the performance of a contract to which the User is a party in order to perform such contract by Duality or in order to take steps at the request of the User prior to entering into a contract, (iii) the necessity for compliance with a legal obligation to which Duality is subject and (iv) the necessity for the purposes of the legitimate interests pursued by Duality or by a third party (i.e. the User), except where such interests are overridden by the User’s legitimate interests and rights. 

Duality may collect the Personal Data by: (1) User submits Personal Data in connection with the Services provided by Duality (e.g. inquiries, questions) or gives separate consent (e.g. newsletter,, marketing), (2) the Duality provides technical assistance or support regarding the Services, (4) Personal Data is collected automatically (e.g. cookies). 

  1. Type of the information and Personal Data collected by Duality

Depending on the type of the Services and the characteristics of consents granted by the User, Duality uses one or more information and the Personal Data: (1) name/surname, (2) e-mail address, (3) phone number, (4) IP address and other technical information (e.g. regarding type of devices and other informatic tools, web browser), (5) information necessary to provide technical assistance or support (e.g. parameters, logs, other descriptions), (6) information necessary for participation in events organized by Duality, (7) other information connected with use of the Services provided by Duality (e.g. residence address and correspondence address). Duality applies all required by law (binding on the territory of European Union or Member State Law) security measures as regards the Personal Data. 

  1. Transfer of the Personal Data

Duality may be entailed with transfer of the Personal Data to reliable and professional partners (processors). Transfer shall be based on the processing agreement concluded between Duality and processor. Duality: (i) transfers the Personal Data regarding the necessity for realization the aim agreed with processor, (ii) transfers the Personal Data solely for the purposes of such aim, (iii) applies all required legal and technical measures for protection of the Personal Data in order to ensure the highest Services quality, (iv) may transfer Personal Data to third parties providing day-today services for Duality (e.g. legal and tax advisors) or other entities entitled to access Personal Data upon binding legal regulations (e.g. administrative bodies). 

  1. The Users’ rights

The User is entitled to exercise his rights concerning Personal Data at any time, in particular: (i) the right to forbid processing of his Personal Data, (ii) access to the Personal Data, (2) request to rectify, correct or delete the Personal Data, (3) request to restrict the processing of the Personal Data, (4) request to transfer the Personal Data to another entity, (5) submit complaint to a data protection authority – President of the Data Protection Office or other offices. In some cases exercising one or more of such rights may result in limitation of use one or more of the Services provided by Duality (due to the necessity of processing Personal Data in accordance to such Services). Duality shall provide the User a response indicating activities and their justification, thus it may be also obliged to store the Personal Data upon binding law regulations.

  1. Cookie Files

The User uses cookies technology during using websites owned by and/or administrated by Duality (hereinafter the “Websites”). Cookie file is type of information which Duality network server sends to the User’s computer or device upon accessing the Websites. Duality uses or may use cookies files as follows: 1) session files – in order to use technical data saved during use of the Websites and transfer to other sites as well as to use such technical data to improve use of the Websites. Such file will not contain any personal data allowing to identify the User and exits only during given sessions of using the Websites, 2) log files and multiple executive files which may be installed on the User’s computer during login on the Websites in order to save data for the purposes of such login (if applicable). Such files may be used only for comfort of the User in order to avoid further information introduction and verification during following sessions. These files are stored on the User’s computer for an indefinite period of time (may be cleared manually by User). Checking settings in the website browser may be used for verification of cookies files. Limitation of use of cookies files or its settings may influence the scope of use of the Websites by the User. Despite blocking cookie files by the User, most content of the Websites will be still available, however User may not have access to particular functionalities (e.g. registration). 

  1. Additional informations

Use of Duality Services may require use of the external websites and/or devices (i.e.  distributors, Steam, consoles, PS4 Store) depending on the Service. The Company is not responsible for content and/or privacy policies of external websites administrated by third parties or services provided by such third parties. 

Automatic profiling is a decision based solely on automated processing which produces legal effects concerning the User (e.g. use of algorithm which exams behaviour in games or on social platforms, resulting in automatic decision). The Company does not apply automatic profiling.

The Company stores the Personal Data solely for the period necessary for obtaining purpose for which the Personal Data have been collected. However, in some cases, the Company may be obliged to store the Personal Data for a longer period by binding regulations (e.g. settlement, tax issues). However, in each case data retention is based on appropriate legal base – e.g. consent or binding provision of law.

Use of the Services requires acceptance of this Privacy Policy. 
The User is allowed to contact with the Company throughout e-mail address: and/or by traditional post on address: Duality S.A. 00-810 Warszawa, ul. Srebrna 16 lok. 308D, Poland