Privacy Policy
Dated: April 29, 2025
This Privacy Policy constitutes a legally binding agreement between you (“You” or “User”) and JNT GAMES sp. z o.o., a company incorporated under the laws of Poland, with its registered office at Technologiczna 2, 45-439 Opole, Poland (“JNT GAMES”, “Company”, “We”, or “Us”).
We are committed to respecting your privacy and ensuring the security of your personal data. All processing is conducted in compliance with applicable privacy laws and this Privacy Policy. We implement appropriate technical and organizational measures in all jurisdictions where we operate or where the law applies to us.
PLEASE READ THIS POLICY CAREFULLY. IF YOU DO NOT AGREE TO ANY UPDATED TERMS, OR IF YOU DO NOT MEET THE AGE REQUIREMENTS SPECIFIED HEREIN, OR IF YOUR ACCESS OR USE OF THE SERVICES IS PROHIBITED UNDER THE LAWS OF YOUR JURISDICTION, YOU MUST IMMEDIATELY DISCONTINUE YOUR USE OF THE SERVICES.
For any inquiries, contact us at office@jntgames.com.
Table of Contents
Definitions
Controller means JNT GAMES sp. z o.o., which determines the purposes and means of the processing of Personal Data.
Processor refers to any individual or legal entity engaged by the Company to handle Personal Data on its behalf under a contract.
Data Subject / User means any natural person who accesses the Website or uses the Game or related Services provided by the Company.
Personal Data means any information that identifies or can reasonably be used to identify an individual (e.g., username, email address, IP, device identifiers). See Data We Process.
Cookies are small text files stored on a User’s device to support functionality, remember preferences, and collect analytics.
Services refers to functionalities offered through the Website, the Game (Passion Rift), or affiliated platforms (content access, accounts, communications, promotions, integrations).
Relevant Legislation includes the EU GDPR, CCPA/CPRA, VCDPA, NY SHIELD Act, and other applicable regimes.
Standard Contractual Clauses (SCCs) are EU-approved terms for lawful transfers of Personal Data outside the EEA.
Sensitive Personal Data includes data requiring enhanced protection under applicable law.
Supervisory Authority refers to an independent data protection regulator (in Poland: UODO – Urząd Ochrony Danych Osobowych).
Consent, Profiling, Personal Data Breach — as commonly understood under privacy laws.
General Provisions
This Privacy Policy forms part of the overall legal framework governing Your relationship with Us, including the End-User License Agreement (EULA), the Customer Terms and Conditions, and any other policies or notices published on the Website or provided with the Services.
As Data Controller, JNT GAMES defines the purposes and means of processing Your Personal Data and ensures compliance with applicable data protection laws.
| Applicable Legislation | Category of User |
|---|---|
| GDPR (EU Regulation 2016/679) | Users located within the EEA |
| CCPA/CPRA | California residents (USA) |
| VCDPA | Virginia residents (USA) |
| NY SHIELD Act | New York residents (USA) |
We strive to: maintain transparency and accountability; apply adequate technical and organizational measures; ensure lawful, fair, and transparent processing; require processors to comply with laws and contractual safeguards; and enable Data Subjects to exercise their rights effectively.
Your Personal Data Rights and Controls
| Action | Description |
|---|---|
| Right of Access | Request access to Personal Data and processing details. |
| Right to Rectification | Request corrections to inaccurate or incomplete data. |
| Right to Restriction | Request limited processing in certain cases. |
| Right to Data Portability | Obtain a machine-readable copy and/or transfer where feasible. |
| Right to Object | Object to processing based on legitimate interests/public interest or for direct marketing. |
| Right to Withdraw Consent | Withdraw consent at any time without affecting prior lawful processing. |
| Right to Lodge a Complaint | Complain to your local authority (Poland: UODO, ul. Stawki 2, 00-193 Warszawa). |
How to exercise: email office@jntgames.com. We may verify your identity before acting. Some rights may be limited by law. You may authorize an agent with written authorization or power of attorney where permitted. If we deny your request, you may have a right to appeal where applicable.
Data We Process
Legal Bases
- Consent (optional features, marketing, analytics)
- Contract (to provide the Game/Services under the Terms/EULA)
- Legitimate Interests (security, fraud prevention, improvement, support)
- Legal Obligations (e.g., tax/audit/consumer)
Categories
- Registration: username, email
- Optional Profile: year of birth, relationship status, sexual orientation (if voluntarily provided)
- Technical: IP, device IDs, device/browser/OS, language, timestamps
- Cookies & Tracking: interactions with Website/Game
- Communications: support inquiries, feedback
- Usage: in‑game activity, interactions, promotions, purchase metadata
- Payment: transaction records via third-party providers (no full payment credentials stored)
Purposes of Processing
- Provide and operate the Game/Services (accounts, authentication, access, content delivery)
- Facilitate transactions for Credits/Additional Content via authorized providers
- Personalize experience (content, recommendations, promotions) where permitted
- Security and fraud prevention (monitoring, integrity, access protection)
- Communications (support responses, administrative notices, updates)
- Legal compliance (consumer, tax, financial, data protection)
- Research & development (improvements, new features, performance, aggregated analytics)
- Enforcement (investigating potential violations of Terms/EULA or law)
Disclosing Your Personal Data
We may share Personal Data with Service Providers/Processors (hosting/CDN, payments, analytics, ad networks, support), integrations, authorities (where required), in business transfers, with marketing partners (subject to consent), for disputes/legal proceedings, or with others where you give explicit consent. Recipients must protect confidentiality/security and process lawfully. We do not sell Personal Data to unauthorized third parties.
Data Retention
We retain Personal Data only as long as necessary for stated purposes and legal/regulatory/contractual obligations:
- Account/Service Data: while account is active + reasonable period thereafter.
- Technical/Usage Data: shorter durations unless needed for security/fraud/legal; analytics may be anonymized for longer.
- Legal/Compliance Data: as mandated by law (e.g., limitation periods).
- Marketing Data: until you opt out; suppression data retained to honor preferences.
- Backups: encrypted, retained per disaster-recovery policy.
International Transfers
We may transfer Personal Data internationally (including outside the EEA). Safeguards include SCCs, encryption/pseudonymization, access controls, transfer impact assessments, and partner due diligence. We minimize disclosures and challenge disproportionate requests. By using our Services, you acknowledge such transfers subject to safeguards.
Storage and Security of Personal Data
- Storage within the EEA, US, or other jurisdictions where we/our processors operate
- Encryption in transit and, where applicable, at rest
- Role‑based access controls (least privilege)
- Regular security reviews and vulnerability management
- Encrypted backups with restricted access
Processors are contractually bound to maintain confidentiality/security and comply with applicable laws.
Right to Withdraw Consent
You may withdraw consent where processing relies on consent by emailing office@jntgames.com. Withdrawal does not affect prior lawful processing. Refusing or withdrawing essential data may limit provision of Services; withdrawing non‑essential processing (e.g., marketing) will not affect core access.
Contact Details
Controller: JNT GAMES sp. z o.o.
Address: Technologiczna 2, 45-439 Opole, Poland
Email: office@jntgames.com
EU Supervisory Authority (Poland): UODO — ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl
Changes to This Policy
We may update this Policy from time to time. Material changes will be communicated prominently via the Website/Game. Continued use after the effective date constitutes acceptance of the updated Policy.
Appendix 1 — California Notice at Collection (CCPA/CPRA)
Effective Date: April 29, 2025 — Applies to California residents.
This Notice supplements the Privacy Policy. In case of conflict, this Notice governs for California residents.
| CCPA Category | Examples | Purpose |
|---|---|---|
| Identifiers | Username, email, IP, device ID | Accounts, service delivery, fraud prevention |
| Commercial Info | Purchase history, transactions | Fulfil purchases, manage in‑game transactions |
| Protected Characteristics | Age, gender (if provided) | Age‑gating compliance, customization |
| Internet/Network Activity | Device, browsing/interaction logs | Security, analytics, improvement |
| Geolocation (approx.) | Region/city | Location‑based features |
| Inferences | Preferences/interests | Personalization/advertising (where allowed) |
| Email Interaction Data | Open/click timestamps | Campaign effectiveness |
| Voluntary Content | Feedback, surveys, support | Service enhancement/support |
Purposes: provide Services, resolve issues, improve UX/features, marketing/ads, legal compliance, IP protection, analytics/audits, security.
Retention: see Data Retention (e.g., payment records 5–10 years as required; technical data may be anonymized).
Rights: Know, Delete, Correct, Opt‑Out of Sale/Sharing, Limit Sensitive PI Use. We do not “sell” PI in the traditional sense; limited “sharing” for cross‑context behavioral advertising may occur where permitted. Exercise rights/opt‑out: office@jntgames.com.
Appendix 2 — GDPR Compliance Notice (EEA)
Effective Date: April 29, 2025 — Applies to Users in the EEA.
This Notice supplements the Privacy Policy and prevails for EEA residents in case of inconsistency.
International Transfers
Your Personal Data may be transferred outside the EEA. Safeguards include SCCs, partner commitments to GDPR‑equivalent protection, encryption/pseudonymization/access controls, transfer impact assessments, and due diligence.
Potential Risks & Mitigations
We acknowledge differing laws, potential lawful access by authorities, and risks of unauthorized access. We minimize disclosures, challenge unlawful requests, and apply security measures.
Consent to Transfers
By using the Services and agreeing to this Policy, you consent to necessary international transfers subject to safeguards. Your fundamental rights remain enforceable.
Storage/Transfer Practices
SCCs and contractual safeguards; technical measures; regular audits and partner due diligence.
Contact (EEA/GDPR): office@jntgames.com.
Regional UK Note
For UK Users, we apply UK GDPR/DPA 2018 standards, equivalent safeguards to SCCs (UK IDTA/Addendum), and cooperate with the UK ICO where required.