Privacy

PRIVACY POLICY of Donkey Crew Sp. z o.o.

Hello Visitor!

Protecting the privacy of Players of Last Oasis, Forum Users or websites visitors is of great importance to us. Therefore, in accordance with Article 13 (1) and (2) and 14 (1) and (2) of the GDPR, we publish a document explaining the rules of processing of personal data of Players of our game – Last Oasis, of those who register an account on the Forum, visit our websites, make use of our other online Services. This Privacy Policy explains which Personal Data we collect from You and for what reasons, how we process such Data and provides You with the information about your rights in relation to your Personal Data. We encourage You to read our Privacy Policy below for a detailed picture of what Data we collect and how it is used. Thank You for your cooperation, and if You have any questions about our Privacy Policy, please contact us at dpo@donkey.team.

This Privacy Policy constitutes an integral part of the Terms of Use and End User License Agreement of any of our Services You use and when you agree to the respective document regulating the use of our Services, You declare that You are familiar with this Privacy Policy.

The provisions of this Privacy Policy shall apply to any User of our Services, in particular Players of Last Oasis, Forum Users or websites visitors or any other Users of our Services.

The following PRIVACY POLICY is valid from 26 March 2020.

DEFINITIONS

"Controller": Donkey Crew sp. z o.o. with its seat in Wrocław, 47 Stanisławowska Street, 54-611 Wrocław, entered into the register of businesses of the National Court Register under reference number (KRS): 0000722417.

"Personal Data”, “Data": all information about an identified or identifiable natural person through one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual, including the IP number of the device, location data, internet identifier and information collected through cookies or other similar technologies.

"Forum": a forum run by the Controller at https://forum.lastoasis.gg.

"Policy": this "Privacy Policy".

"GDPR": 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.

"You", "User": Any natural person using the Services provided by the Controller.

"Player": Any natural person taking part in Controller’s games, in particular Last Oasis.

"Services": services, games, in particular Last Oasis, any website operated by the Controller and used by the User.

"Profiling”: automated processing of personal data which involves using personal data to evaluate certain personal factors of an individual, in particular to analyse or forecast aspects relating to that individual's performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement.

Donkey Crew, as the creator of "Last Oasis", the owner of the Forum and the following website: lastoasis.gg, and provider of any other online Services is, at the same time, the Controller of Personal Data processed within this Services. This means that we decide for ourselves on the purposes and means of processing this Data. At the same time, we do so in accordance with the generally applicable laws concerning the processing of personal data and this Policy.

As you use our Services, we collect and process your Personal Data. Below you will find detailed rules and purposes of processing of your Personal Data.

FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS WE PROCESS YOUR DATA when you are a Player

When you are a Player using Steam, as a game distributor, we get access to the Data concerning You and your activity as a Player in the following situations:

- when You purchase our games,

- when You play our games,

- when contacting with customer support using e-mail, letters, chat and forum posts,

- when filling surveys in games,

- when participating in research analyzes in games,

- during participation in pre-release tests,

- when signing up for and participating in events,

and we process your Data (Steam name, Steam ID, IP address, password, information about your devices and software used by You, uncontrolled exit report and player device error information, in-game activity including but not limited to what games you play, own, how you play, how often and for how long, multiplayer sessions, when these sessions were played and which players were in them, friend relations added to the Friends List in chat systems in games) for the purposes of the performance of the contract concluded with You (Article 6(1)(b) of the GDPR).

If you give us consent to processing of your Data in order to send you newsletter or any other information concerning our offers, we may process your Data explicitly indicated by You on the basis of your consent expressed for this purpose (Article 6(1)(a) of the GDPR).

We collect your Data and information collected through cookies or other similar technologies when you are a Player logged on Steam. We process them for the purpose of keeping the Player logged on the website used for managing your personal server (Article 6(1)(b) of the GDPR).

We may receive Data about You from our partners or third parties, like for example Steam or Easy Anti-Cheat (EAC) and its third parties. When You link your Last Oasis account with a Steam Account or other account, we may collect Data about You from such account, including your Steam name, Steam ID or VAC ban status. We may also receive Data from third parties (such as game distributors) to add to the Data we possess to prevent fraud and/or abuse.

We are obliged to process your Personal Data in the situation when processing is necessary for compliance with a legal obligation to which the Controller is subject (Article 6(1)(c) of the GDPR), especially for the purpose of ensuring fair practices, preventing fraud and other illegal activities, ensuring compliance with applicable laws and regulations.

We process information concerning your activity in our games, including your Personal Data, as recorded in system logs (a special computer program used to store a chronological record of events and activities concerning the computer system used to provide services) and through analytical scripts. We use this Data primarily for the purposes of providing our Services, for technical and administrative purposes, for the security and management of the IT system, and for analytical and statistical purposes. In this respect, the legal basis for the processing of personal data is our legitimate interest (Article 6(1)(f) of the GDPR). Moreover, we indicate that the Controller processes the Data when processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data subject which require protection of Personal Data, in particular where the Data subject is a child (Article 6(1)(f) of the GDPR). We indicate that our legitimate interests are also the following: maintenance and development of games and Services, delivery of software updates, tracking and fixing bugs, ensuring integrity and security in games, organizing and carrying tests/betatests of game to which Player signed up, establishment, assertion or defense against claims and protecting our rights, protection of unauthorized access.

You may only include personal data of other persons (including their name, address, telephone number or e-mail address) if you do not violate their rights.

FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS WE PROCESS YOUR DATA when you are Forum User

We collect your Data and information collected through cookies or other similar technologies when You use the Forum (including as a non-logged user). We process them for the following purposes:

- to make the content collected on the site available - then the legal basis for processing is our legitimate interest - the distribution of our content (Article 6(1)(f) GDPR);

- for analytical and statistical purposes, in which case the legal basis for the processing is our legitimate interest (Article 6(1)(f) of GDPR) to analyze Users' activities and preferences in order to improve the functionality and services provided;

- in order to possible establishment, assertion or defense against claims, the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR) - protecting our rights;

- for our marketing purposes; the principles of processing Personal Data for marketing purposes are described below under MARKETING.

Your activity on the Forum, including your Personal Data, is recorded in system logs (a special computer program used to store a chronological record of events and activities concerning the computer system used to provide services) and through analytical scripts. We use this data primarily for the purposes of providing our services, for technical and administrative purposes, for the security and management of the IT system, and for analytical and statistical purposes. In this respect, the legal basis for the processing of personal data is our legitimate interest (Article 6(1)(f) of the GDPR).

Registration

To create an account on the Forum, you are asked to provide the Data and information necessary to create and operate the account, i.e:

- username,

- e-mail address,

- your preferences regarding the use of the Forum,

In addition, for ease of use, You may provide additional data - such data may be deleted at any time. The submission of data marked as mandatory is required in order to set up and operate an account, and failure to submit such Data will result in the impossibility of setting up an account. Providing a nickname, which You use to sign your posts and comments, is obligatory for You to use the Forum. The remaining Data is optional.

In connection with the creation and maintenance of the Forum account we process your Data for the following purposes:

1. in order to provide services related to the maintenance and operation of the account on the Forum - the legal basis for the processing is the necessity of the processing for the performance of the contract (Article 6(1)(b) of the GDPR) and with regard to the Data provided on an optional basis - the legal basis for the processing is consent (Article 6(1)(a) of the GDPR);

2. for analytical and statistical purposes - the legal basis for the processing is our legitimate interest (Article 6(1)(f) of the GDPR), consisting in conducting analyses of Forum Users' activity and account usage, as well as their preferences, in order to improve the applied functionalities;

3. in order to possible establishment, assertion or defence against claims - the legal basis for the processing is our legitimate interest (Article 6(1)(f) of the GDPR) - protecting our rights;

4. for our marketing purposes, the principles of processing personal data for marketing purposes are described below under MARKETING.

You may only include personal data of other persons (including their name, address, telephone number or e-mail address) if you do not violate their rights.

FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS WE PROCESS YOUR DATA when you are Visitor of our websites or User of our other online Services

Donkey Crew is the owner of the websites and the Controller of Personal data of Users of the following websites: lastoasis.gg and donkey.team

We process information concerning your activity on our websites, including your Personal Data, as recorded in system logs (a special computer program used to store a chronological record of events and activities concerning the computer system used to provide services) and through analytical scripts. We use this Data primarily for the purposes of providing our Services, for technical and administrative purposes, for the security and management of the IT system, and for analytical and statistical purposes. In this respect, the legal basis for the processing of personal data is our legitimate interest (Article 6(1)(f) of the GDPR). Moreover, we indicate that the Controller processes the Data when processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data subject which require protection of Personal Data, in particular where the Data subject is a child (Article 6(1)(f) of the GDPR). We indicate that our legitimate interests shall be also maintenance and development of websites and Services.

We collect your Data and information collected through cookies or other similar technologies when You use the Forum (including as a non-logged user). We process them for the following purposes:

- to make the content collected on websites available and to ensure the best performance of the websites - then the legal basis for processing is our legitimate interest - the distribution of our content (Article 6(1)(f) GDPR);

- for analytical and statistical purposes, in which case the legal basis for the processing is our legitimate interest (Article 6(1)(f) of GDPR) to analyze Users' activities and preferences in order to improve the functionality and services provided;

- in order to possible establishment, assertion or defense against claims, the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR) - protecting our rights;

- for our marketing purposes; the principles of processing Personal Data for marketing purposes are described below under MARKETING.

We may also process your Data for marketing purposes if You have given your consent by subscribing to the newsletter on our website.

Controller may be associated with the following pages:

https://store.steampowered.com/app/903950/Last_Oasis/

https://donkeycrew.atlassian.net/servicedesk/customer/portals

https://www.donkey.team/privacy

lastoasis.gg

https://trello.com/

https://www.zendesk.com/

https://discordapp.com/invite/lastoasis

https://steamcommunity.com/app/903950

https://www.twitch.tv/teamdonkeycrew

https://mixer.com/DonkeyCrew

donkey.team

provided that processing of Data of the Users shall be regulated by the provisions of respective privacy policies of the owners of the abovementioned websites.

To the extent that the issue of processing of Personal Data is not governed by the privacy policy of the owners of the above mentioned websites, the provisions of this Policy shall apply.

Controller may also process Data of the Users of social networks such as Facebooka, Instagram, Twitter, Youtube and other similar. To the extent that the issue of processing of Personal Data is not governed by the privacy policy of the owners of the above mentioned websites, the provisions of this Policy shall apply.

Controller may also use Googleforms while providing Services and in the event of processing of Personal Data within such forms, the form shall include the clause concerning the purpose of Data processing and shall enable the User to express his consent in such form. Such Data processing shall made on the basis of the consent of the User (Article 6(1)(a) GDPR).

You may only include personal data of other persons (including their name, address, telephone number or e-mail address) if you do not violate their rights.

MARKETING

We process the data provided by You on Steam and made available to Donkey Crew by Steam for the marketing purposes to the extent limited by Steam's PRIVACY POLICY https://store.steampowered.com/privacy_agreement/english/

and any consents you may have given to Steam.

We also process your Data for marketing purposes if You have given your consent through your Forum account or by subscribing to the newsletter on our website.

We only use your Data for displaying marketing content independent of your preferences (standard advertising). Standard advertising is advertising that is independent of User preferences.

COOKIES AND SIMILAR TECHNOLOGY

Cookies are small text files installed on your device. The rules of cookies processing are presented in the “Cookie usage”:

https://www.donkey.team/privacy#h.p_7Y8IiUhDPUk0

DURATION OF PERSONAL DATA PROCESSING

The processing time of your data depends on the basis of this processing, its purpose and the way in which we collect this data.

If you have provided us with your Data in the context of registering for the Forum, we will process your Data as a rule for as long as You have an account and then until the statute of limitations for mutual claims. However, those Data that we process within the Forum, based on your consent, will be processed until You delete your account in the Forum or until you withdraw your consent.

If You have subscribed to our newsletter, we will process your Data for this purpose for a period of 10 years from the date of your consent, unless you withdraw your consent beforehand.

If you have made your Data available to us by the Steam platform, after You have purchased our game, we will process your Data for as long as you have the opportunity to use this game under the relevant license, and then until the statute of limitations for mutual claims, unless You waive your right to use the game first and inform us about it.

If you have provided us with your Data via the Google form, we will process it for a period of 10 years from the date on which You consent to this processing.

The duration of processing may be extended if the processing is necessary for the establishment, investigation or defense of possible claims, and after that period, only if and to the extent required by law.

YOUR RIGHTS

You have the right to: access your Data and request its rectification, deletion, restriction of processing, the right to transfer the Data to another controller and the right to object to the processing of the Data, as well as the right to lodge a complaint with the Data protection supervisory authority.

To the extent that your Data is processed on the basis of your consent, You may withdraw it at any time by contacting us in accordance with the data provided in the Forum. You may, at any time, withdraw your consent to the processing of your Personal Data without affecting the lawfulness of the processing carried out on the basis of this consent before its withdrawal.

Right to object

You have the right to object to the processing of your Data at any time:

- for direct marketing purposes;

- for reasons relating to your specific situation in cases where the legal basis for processing your Data is our legitimate interest (e.g. our marketing, statistical, analytical purposes), i.e. when your Data are processed pursuant to Article 6(1)(f) of the GDPR;

How to exercise your rights, including withdrawal of consent

in order to exercise the rights described above, just:

- in the case of the Forum, check the appropriate option in your account settings

- in the case of the newsletter, You can revoke your consent by clicking on the special link in each newsletter

- in any other case, You can contact us by e-mail at the address: dpo@donkey.team

DATA RECIPIENTS

In connection with the provision of our Services, your Personal Data may be disclosed to third parties, including, in particular:

- Steam https://store.steampowered.com/

- Easy Anti-Cheat (EAC) and its Third Parties https://www.easy.ac/en-us/

- Nitrado https://server.nitrado.net/pol/rent-gameserver

as well as providers responsible for the operation of IT systems used to provide Services, including Forum management, and marketing agencies (for marketing services) and entities that are related to us.

Your Data may be disclosed to competent authorities or third parties who request such information, based on the relevant legal basis for providing the information and in accordance with applicable law.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

It is possible that we will transfer your Data outside the European Economic Area (EEA) - in particular to United States of America, where some of the third parties’ servers are placed. Such a transfer outside EEA will only take place if an adequate level of protection of your Data is ensured, which will be determined in particular by means of:

- cooperation with processors of personal data in countries for which a relevant European Commission decision has been issued;

- the use of standard contractual clauses issued by the European Commission;

- applying binding corporate rules approved by the competent supervisory authority;

- in the case of transfers to the US, cooperation with entities participating in the Privacy Shield Programme, approved by a European Commission decision.

We will provide You with a copy of your Data that will be transferred outside the EEA upon your request.

WHETHER THE PROVISION OF DATA IS MANDATORY

Whether the provision of data is mandatory depends on the type of data and the basis on which it is processed.

If we process your Data in connection with your use of the game, your data is passed to us by Steam. In this case, Steam's PRIVACY POLICY and any consent you have given to Steam will apply.

If you wish to create an account on the Forum, it is mandatory to provide most of your data, but the provision of additional data that we process on the basis of your consent is voluntary. It is also voluntary for You to express your consent for processing of your e-mail address for marketing purposes.

You also voluntarily consent to our processing of your e-mail address for marketing purposes, which You provide on our website.

PROFILING

We will not make any decisions concerning You based solely on automated decision-making, including profiling.

PERSONAL DATA SECURITY

We carry out risk analysis on an ongoing basis to ensure that Personal Data is processed by us in a secure manner, ensuring in particular that only authorised persons have access to the Data and only to the extent that this is necessary for their tasks. We make sure that all operations on Personal Data are recorded and performed only by authorized employees and associates.

We take all the necessary steps to ensure that our subcontractors and other cooperating entities also guarantee the application of adequate security measures whenever they process Personal Data on our behalf.

CHILDREN

Controller will not intentionally process the Personal Data of children under age of 16. Where the child is under the age of 16, and the Personal Data of the child is processed on the basis of its consent, Controller requires parental consent before the child uses any of the Services provided by the Controller. Controller encourages Users to cooperate with holder of parental responsibility over the child in such manner to obtain his/her consent before using any of the Services provided by the Controller. Controller encourages holders of parental responsibility over the child to instruct the child not to share their personal information online.

If we process the Data of children in connection with use of the game, such Data is passed to us by Steam. In this case, Steam's PRIVACY POLICY and any consent given to Steam will apply.

For more information, please check https://store.steampowered.com/privacy_agreement/

CONTACT DETAILS

Contact with us is possible via e-mail: dpo@donkey.team or in writing to the address: 47 Stanisławowska Street, 54-611 Wrocław.

We have appointed a Data Protection Inspector who can be contacted at the above-mentioned e-mail address.

CHANGES TO THE PRIVACY POLICY

The Policy is reviewed and, if necessary, updated on an ongoing basis.



COOKIES

1. The websites of lastoasis.gg and donkey.team use cookies.

2. Cookies (so-called "cookies") are IT data in the form of small text files which are sent by the server and stored on the your final device (e.g. on the computer hard disk or in the memory of a smartphone) and are intended to be used on websites. Cookies typically contain the name of the website from which they originate, the duration of their storage on the terminal equipment and a unique number.

3. The entity placing cookies on the terminal device and gaining access to them is the website Controller or entities, which provides him with services.

4. The website use the following types of cookies files.

a) Analytics cookies – measure how you interact with website content. As you navigate between web pages, they provide JavaScript tags (libraries) to record information about the page you have seen. Analytics JavaScript libraries use HTTP Cookies to "remember" what you have done on previous pages / interactions with the website.

b) Performance and functionality cookies - These cookies are used to enhance the performance and functionality of your website, but are not essential to its use. However, without these cookies, certain functionality (like videos) may become unavailable.

c) Essential cookies - Essential cookies are a website’s basic form of memory, used to store the preferences selected by you on a given site. As the name implies, they are essential to the website’s functionality and cannot be disabled by you. For example, an essential cookie may be used to prevent you from having to log in each time they visit a new page in the same session.

d) Advertising and targeting cookies – These are cookies that are used to deliver content that best suits you and your interests. It can be used for targeted advertising / offers, limiting ad serving or measuring the effectiveness of a promotional campaign. We may use these cookies to remember the sites you visit, in order to determine which e-marketing channels are more efficient and allow us to reward partners and external websites.

5. The website does not automatically collect any information, except for information contained in cookies.

6. The Controller may process the data contained in the Cookies files while using the Website by the visitors for the following purposes:

- adjust the content of the Website to the Client's individual preferences (e.g. concerning language);

- remember the IP location and time zone;

- advertise his products and services;

- collect anonymous statistics showing how visitors use the Website, i.e. to study the behavioural characteristics of visitors to the Website through an anonymous analysis of their activities (e.g. repeated visits to specific pages, keywords, etc.), which help to better understand how visitors use the website, thus enabling the website to better match the preferences and behaviour of visitors;

- Controller's use of services provided by third parties, i.e. Google LLC in the form of Google Analytics tools. In addition, the website may contain links to other websites, such as Google Maps and others. These companies use their own cookies, which are not under the control of the Controller.

7. Default settings for web browsing software (web browser) typically allow you to obtain and store information or access information already stored on your telecommunications terminal device, including cookies. You can determine the terms and conditions of the use of cookies by setting their own internet browser. This means that you can, for example, delete cookies, partially limit the number of cookies you can store (e.g. temporarily) or completely disable the storage of cookies - in the latter case, however, this may affect certain functionalities of the website.

8. Your browser's cookies settings are important for your consent to the use of cookies by the website. Such consent can also be given through your browser settings.

9. In case of disagreement with the use of cookies by a visitor to the website, these settings can be changed in such a way as to block the automatic handling of cookies in the settings of the Internet browser, or inform about each time they are sent to the your device. You may also delete files from his/her device every time he/she visits the website.

10. For detailed information on how to use and change or delete cookies, please refer to your Internet browser's help or documentation.

11. Controller may use Google Analytics, Universal Analytics, provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). These services help Controller analyze traffic on the Web Site. The collected data are processed within the framework of the above services in an anonymous way (these are the so-called exploitation data, which make it impossible to identify a person) to generate statistics helpful in administering the Website. These data are aggregated and anonymous, i.e. they do not contain any identifying features (personal data) of persons visiting the website. Using the above services in the Web Site, the Controller collects data such as sources and medium of obtaining visitors to the Web Site and the way they behave on the Web Site, information on the devices and browsers from which they visit the site, IP and domain, geographical data and demographic data (age, sex) and interests.

12. You may refuse the use of Google Analytics to provide information about your activities on the Website by selecting the appropriate browser add-on from Google Inc.

13. Limitations on the use of cookies may affect certain features of the website. Deactivating the use of cookies may make it difficult or, in extreme cases, impossible to use the website.