Warhorse Privacy Policy 

MARCH 2024 

This Privacy Policy applies to this website of Warhorse Studios s.r.o. Voctářova 2500/20a, 180 00, Prague  8, Czech Republic (hereinafter "WHS" or also “we”) and provides for the rules and methods how we protect your personal data. 

In accordance with the   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 (hereinafter “GDPR regulation” or just “GDPR”) and the act of the Czech Parliament no. 110/2019 Sb. on processing the personal data (hereinafter the “Act”) we are the controller of your personal data.  

 

WHS is serious about protecting users’ privacy and personal data. Our data protection practices and this privacy policy complies with the GDPR and the Act.  We process your data only for the purposes described herein. We will only collect the information we need to provide our services to you and to pursue our legitimate interests. We shall only send you advertising or share your information with third parties if legally allowed to do so or with your explicit consent. Furthermore, we process your data if we are obliged to do so by law. 

We ensure that the law and this Privacy Policy are respected by us, our employees and external service providers who work or otherwise carry out services for us. For this we have taken appropriate technical and organizational measures, which correspond to the state of the art (more information under Security of data). 

1. Definitions 

1. Personal Data  

Personal Data means any information relating to an identified or identifiable natural person. Personal Data is one that identifies you directly or indirectly (also in conjunction with other data) and that can be used to contact you online or offline. Examples of personal data are: Name, address, phone number, email address, user ID, IP address, location, payment information (credit card number, bank details). 

1. Non-personal Information  

Non-personal data cannot be used to identify or contact you. We may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches when you use our website (see below for details). 

1. How we collect Personal Data? 

We collect the following personal data when you subscribe to our newsletter or you with to contact us through our website 

1. Name and surname 

1. Email address 

Newsletter 

With your consent, we will be happy to send you our newsletter. To do this, you must register for our newsletter. More details on the content of the newsletter in question are explained in the declaration of consent or on the registration page for the newsletter.  

You can sign up for our free newsletter on our website. For the registration to our newsletter we use a double opt-in procedure for GDPR compliance provided that GDPR applies to the country from which you are registering. After your registration, we will send you a message to the specified e-mail address with a link that you can click to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your details will not be used to send the newsletter and will be deleted after one week. In addition to your e-mail address, we collect and save the time of the submission of your consent. Only then can we document that you have voluntarily registered. 

We also point out that we evaluate your user behavior when sending the newsletter, i.e., we can see if you open the newsletter or click on links contained in the newsletter. For this evaluation, our newsletter includes a so-called "web beacon". This is a pixel-sized file that we use to analyze the reach and success of our newsletter and tailor it to your needs. For the evaluations, we link the aforementioned data and the web beacons with your e-mail address and an individual ID. Links contained in the newsletter also contain this ID. The IDs are linked with further personal data from you including your name, Account and user profile, country, and technical data such as browser and operating system. By evaluating this data, we can assess the general use of the newsletter and gain insights into which content and parts should be further improved and developed according to user habits. This helps us to further personalize the newsletter to your interests and preferences. 

Your data will only be used to send, evaluate, and personalize newsletters. We store your data only as long as the subscription to the newsletter is active.  

If you're receiving our newsletter in the European Union or the European Economic Area, Switzerland, or the UK, the legal basis for the related data processing is Art. 6 para. 1 lit. a GDPR or the corresponding provision in the Swiss and UK legislation, as the newsletter is only sent and evaluated with your consent. You can revoke your consent and cancel the subscription at any time with effect for the future. You will find a unsubscribe link in each newsletter. 

Contact form  

You can contact us by e-mail or through our contact form at any time and contact our support team. In this case, the Personal Data transmitted by e-mail or with your inquiry will be stored. The data is used exclusively for communication. 

The basis for the processing is our legitimate interest to respond to your request as requested and is based on Art. 6 para. 1 lit. f GDPR. 

The data will be deleted as soon as it is no longer necessary for the purpose of its collection.  

You can object to the storage of your data at any time. However, a proper response to your inquiry can then no longer be guaranteed in individual cases. 

1. How we collect non-personal information 

 

Through our website - www.warhorsestudios.cz  

Log file data 

When you visit our website, access data is recorded in the log file on our servers. We record: Internet protocol, address / IP address, page from which the file was requested, date, time, browser type and operating system, page visited, data transfer, access status (file transfer, file not found, etc.).  

We use the log files to ensure the functionality of the website, to monitor traffic on our website, to resolve technical issues, and to generate statistics that help us tailor our services to your needs. This is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.  

We do not store this data together with your personal sata. If it comes to an abuse of our website, we can block IP addresses, if necessary. The data is stored only for a limited period of time and only for as long as necessary to ensure the safety and functionality of our website.  

Cookies / Pixels 

WHS uses cookies and similar technologies to 

• to ensure that our website function properly; 

 

Cookies are small files that are used in your internet browser to track movements within web pages and to allow analysis of web page usage. We may connect cookie information with Personal Data. 

Technically necessary cookies 

The purpose of using technically necessary cookies is to facilitate the use of website. Cookies store, for example, to save language settings or to remember search requests. 

The processing of personal data, as the case may be, using Cookies and similar tracking technologies serves our legitimate interest and is based on Art. 6 para. 1 lit. f GDPR. 

Analysis, tracking and advertising cookies 

The use of the analysis cookies is for the purpose of improving the quality and content of our website.  

You can restrict, deactivate and delete the use of cookies in your browser settings at any time (see Restricting / Deactivating cookies).  

We set this type of cookies only with your prior consent, Art. 6 para. 1 lit. a GDPR. When you visit our website for the first time, you can give or refuse your consent via a tool (consent tool). Here you will also find detailed information about the cookies we use. 

Third party cookies  

Our website does not contain third party advertisements and therefore does not use third party cookies.  

Google tools 

Our website use several services offered by Google. Google stores data on its own Google servers around the world. Most of them are located in the USA. At https://www.google.com/about/datacenters/locations/?hl=de you can find out exactly where the Google servers are located. If you have consented to the use of Google tools (see analysis, tracking and advertising cookies) and we transmit data to Google in the USA, your personal data are protected by separate order processing agreements, which include standard contractual clauses approved by the EU commission to ensure the security of your data, between Google and WHS (for more information see Section 5.). 

Information of the third party provider:  

Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (“Google”). 

Privacy policy Google: https://policies.google.com/privacy 

Google Analytics  

If you have given your consent, our website uses Google Analytics, a web analysis service of Google. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). 

Scope of processing 

Google Analytics uses cookies that enable an analysis of your use of our website. The information collected by the cookies about your use of this website is usually transferred to a Google server in the USA and stored. 

We use the function ‘anonymizeIP’ (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP-address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google. 

During your website visit the following data will be collected: 

• the pages you call up, your “click behavior“ 

• Achievement of “website goals” (conversions, e.g. newsletter registrations, downloads, purchases) 
• Your user behavior (for example clicks, dwell time, bounce rates) 
• Your approximate location (region) 
• Your IP address (in abbreviated form) 
• technical information about your browser and the end devices you use (e.g. language settings, screen resolution) 
• your internet provider 
• the referrer URL (via which website/advertising medium you came to this website) 

Purposes of processing 

On behalf of the operator of this website, Google will use this information to evaluate your pseudonymous use of the website and to compile reports on website activity. The reports provided by Google Analytics serve to analyze the performance of our website and the success of our marketing campaigns. 

Recipient 

The data recipient is 

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland 

as data processor. For this purpose we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google. 

Duration of storage 

The data sent by us and linked to cookies is automatically deleted after 14 months. Data is automatically deleted once a month as soon as the storage period is reached. 

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by 

1. not giving your consent to the setting of the cookie or
2. downloading and installing the browser add-on to disable Google Analytics HERE LINK TO OPT OUT INSERT.

By setting your browser software accordingly you can also prevent the storage of cookies. If your browser is set to refuse all cookies, the functionality of this and other website may be limited. 

For more information, see Cookies.  

More information about Google Analytics can be found at  

https://support.google.com/analytics/answer/6004245?hl=de&ref_topic=2919631 

Restrict / Deactivate cookies 

Cookies are stored on your computer and transmitted by it to our website. Therefore, as a user, you have full control over the use of cookies. You can deactivate the use of cookies in your browser settings at any time and delete already stored cookies. This can also be done automatically. 

Most browsers are automatically set to accept cookies. If you do not wish to have cookies stored on your computer or to be informed about their storage, you can prevent the installation of cookies by adapting your browser software accordingly. In your browser settings, activate the option "Do not accept cookies" or "Do not track" (different depending on your browser). The instructions of your browser manufacturer will give you more information on how this works. However, we would like to point out that by preventing Cookies you may not be able to use all the functions of the website to the fullest extent. 

Some of our website also use flash cookies - also known as "locally shared items" - on our website. Flash cookies are small files, much like browser cookies, and are used to customize the design of web pages and store those requests. Flash cookies only collect aggregated data. Like normal cookies, flash cookies are small files on your computer. You can prevent flash cookies by adjusting your settings in the Macromedia website privacy settings panel at www.macromedia.com. 

Please note that this Privacy Policy covers only the use of cookies by WHS, but not the use of cookies by other advertisers. 

1. Lawful grounds for the processing of your Personal Data 

Insofar as we obtain the consent for processing of Personal Data, Art. 6 para. 1 lit. a GDPR serves as lawful ground. 

If the processing of Personal Data is necessary for the performance of a contract to which you are a party to, Art. 6 para. 1 lit. b GDPR serves as lawful ground. This also applies to processing activities prior to entering into a contract. 

Insofar as processing of Personal Data is required to fulfill a legal obligation we are subject to, Art. 6 para. 1 lit. c GDPR serves as lawful ground. 

Insofar as processing of personal data is necessary for the performance of a task carried out in a vital interest of the data subject or another natural person, or in the public interest, Art. 6 para. 1 lit. d and lit. e GDPR serve as lawful ground for processing. 

If processing is necessary to pursue our legitimate interests, and if your interests, fundamental rights and freedoms do not prevail over our interest, Art. 6 para. 1 lit. f GDPR serves as lawful ground for processing. Our legitimate interests include, inter alia, the assertion, exercise or defense of civil claims or the operation of our website.  

1. How long will your Personal Data be stored  

We will process and store Personal Data no longer than necessary for the purposes for which they have been collected. Subsequently, the Personal Data will be deleted in accordance with the statutory provisions. 

In general, your Personal Data will be stored during the term of our contractual relationships. However, in some cases, Personal Data may be stored for longer due to EU regulations, laws or other regulations to which we are subject or for as long as the retention of Personal Data is required due to other legal reasons (e.g. in accordance with Art. 17 para. 3 GDPR). This may include keeping your Personal Data after you have deactivated your account for the necessary period for us to pursue legitimate business interests, comply with (and demonstrate compliance with) legal obligations, resolve disputes or enforce our agreements. If there are legitimate reasons opposing a deletion, for instance statutory retention or storage periods, processing of these data will be limited. In such case the data will be erased as soon as the reason for further storage ceases to exist, for example if the statutory retention period expires. 

Is the right to process Personal Data based on your consent in accordance with Art. 6 para. 1 lit. a GDPR the data will be deleted as soon as the purpose of the storage is canceled or if you revoke your consent. A revocation is possible at any time. The revocation of your consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. 

1. How do we disclose Personal Data? 

Transfer to our service providers 

We share your Personal Data with a limited number of third-party service providers who process it on our behalf to provide our Platform Services, and who have agreed to privacy restrictions similar to our Privacy Policy. These service providers may help us to host our website or provide (technical) support, among others. We have entered into data processing agreements with our service providers. Therefore, those transfer of data are covered by Art. 28 GDPR.  

Transfer to affiliated companies and other third parties 

Insofar as it is necessary for internal administrative purposes or our business operations or in case we have obtained your consent, we may share your Personal Data globally with companies of the WHS Group (to affiliates, subsidiaries and the parent company). When transferring and using the data, we always comply with data protection regulations and the scope of your consent. The affiliated companies may also use the data for their own purposes, e.g. direct advertising for their own services.  

Due to the corporate structure, WHS has a legitimate interest in the transfer of Personal Data within the group to the extent necessary for administrative or operational services pursuant to Art. 6 para. 1 lit. f GDPR.  

Any other transfer to third parties will only take place if this is necessary for the fulfillment of the purpose of the contract, we can invoke our legitimate interest or you have given us your consent. 

Transfer for legal or law enforcement reasons 

WHS may also disclose Personal Data to law enforcement  or the relevant civil authorities to enforce legal rights and to comply with the law, or to comply with a decision by a government or other competent authority, or if we have reason to believe that disclosure is required to respond to potential or actual violations or interference with our rights, property, reputation, business operations, users or others who may be harmed, or if we believe disclosures are required to protect our rights or us against fraud, or to comply with any lawsuit, court order or legal process served. 

Corporate transactions 

In the context of corporate transactions (acquisition, sale, restructuring of companies or company shares), third parties may gain access to your Personal Data. Disclosure for this purpose serves our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. 

1. Do we transfer Personal Data internationally? 

We do not transfer your personal data outside of EU.  

1. Security of your personal data 

We commit ourselves to data security within the framework of the applicable data protection laws and current IT security standards. Your Personal Data is protected against unauthorized access and loss through the use of various electronic, technical, physical, administrative and contractual measures. WHS has taken the necessary technical and organizational precautions to ensure that to both internally and by external service providers fully comply with our Privacy Policy. 

We adhere to generally accepted industry standards to protect personal and non-personal data for both transmission and storage. 

All WHS employees are required to comply with data security and privacy policies, and have appropriate instructions and are trained on a regular basis. 

For payment transactions, your data is encrypted using the SSL process. Our employees and or payment providers are not authorized to request further user data such as bank details or passwords. 

Persons requiring access for technical, business, or editorial maintenance of the server and portal are legally bound by a confidentiality and non-disclosure agreement 

Please note, however, that no electronic communication or electronic storage method is completely secure. We remind you that despite our high standards, information that you voluntarily provide in the internet is never guaranteed to be 100% secure. There is always the danger that third parties will gain unauthorized access. While we strive to use all commercially reasonable means to protect your personal information, we cannot guarantee absolute security.  

1. Your legal rights 

You can revoke a given consent at any time. To ensure the security and integrity of your Personal Data, we may ask you for additional information in justified cases to verify that you are the owner of that data. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.  

You can also request information from us at any time as to which Personal Data we process from you (Right of Access, Art. 15 GDPR). Insofar as the data concerning you is incorrect or incomplete, you have a Right of Rectification (Art. 16 GDPR). In certain cases, you have the right to request a restriction of processing. Details can be found in Art. 18 para. 1 GDPR. 

You can demand that the Personal Data concerning you shall be deleted immediately (Right to Erasure, Art. 17 GDPR). In particular, we are required to immediately erase this information if the data is no longer necessary for the purposes for which it was collected or if you revoke your consent. Further deletion obligations can be found in Art. 17 para. 1 GDPR. 

Please note, however, that statutory provisions provide for a retention period and we are allowed to store data for the settlement of disputes, for the enforcement of our Terms of Use and due to technical and legal reasons (e.g. backup files). This data may only be deleted after periods of time specified by law. 

If you have the right to rectify, delete or restrict the processing by us, we are obliged to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort (Notification Obligation, Art. 19 GDPR). You also have the right at any time, for reasons arising from your particular situation, to prevent and object the processing of your Personal Data, pursuant to Art. 6 para. 1 lit. e or f GDPR. 

You also have the right to receive personally identifiable information you provide to us in a structured, common and machine-readable format. You also have the right to transfer this data to another person without hindrance (Right to Data Portability, Art. 20 GDPR). 

Please note that in we may reasonably ask you for additional information to verify that you are the owner of this data. This is for the security and integrity of your data. 

Without prejudice to any other administrative or judicial remedy, you have the right to file a complaint to a supervisory authority, in particular in the Member State of residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is violates the GDPR. 

1. Modification of the Privacy Policy 

WHS reserves the right to modify and update this Privacy Policy at any time in accordance with applicable privacy laws. If we change our Privacy Policy, we will post those changes to this Privacy Policy, the website or other places so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Please visit this page frequently. 

1. Questions and comments 

If you have any questions, concerns or remarks about data privacy, please contact us by email to [email protected].