Privacy Policy

§ 1Introduction

Passionnet Sp. z o.o., with its registered office in Warsaw (00-363), ul. Nowy Swiat 54/56, entered in the register of entrepreneurs of the National Court Register under number 0000897484, NIP 5252861218 (hereinafter the "Company" or the "Administrator"), respects the privacy of users of its services. This Privacy Policy describes how we collect, use, disclose, and protect information about users while they use our website and services related to the detective game "Murder Mystery Files" (the "Service"). By using the Service, the User accepts the rules described in this Privacy Policy. If the User does not agree, they should stop using the Service and related services.

Our services are not intended for persons under 16 years of age; we do not knowingly collect personal data from children under this age. Minors aged 16 to 18 may use the Service only with the consent of a parent or legal guardian.

§ 2Information we collect

We collect various types of information to provide and improve our services and to deliver a better user experience. These categories include:

§ 3How we use the collected information

We use the collected personal data for the following purposes:

• Providing services and account management: to create and manage the User account and enable access to Service features (for example, access to exclusive content for registered players).
• Sales and delivery of the game: to process orders, handle payments for our physical game, and provide customer support (including delivery to the specified address).
• Personalized gameplay: to provide access to personalized content within the game (such as the interactive map or individual PDF documents related to the storyline).
• Improving the Service: to analyze user behavior and feedback to improve functionality, content, and service quality.
• Marketing communication (with consent): to send marketing emails about updates, promotions, or new products if the User has explicitly agreed.
• Legal obligations: to meet legal requirements (for example, tax or accounting obligations) and enforce our Terms of Service.

§ 4Legal bases for processing

We process Users' personal data only within the limits allowed by data protection laws, in particular the EU General Data Protection Regulation (GDPR). Depending on the situation, the legal basis is:

• Performance of a contract (Article 6(1)(b) GDPR): Processing data provided during account registration and game purchase is necessary to perform the service agreement (account management and access to the game) and the sales agreement for the physical product.
• Consent (Article 6(1)(a) GDPR): If we send marketing information electronically (such as newsletter emails), we rely on the User's voluntary consent, which can be withdrawn at any time.
• Legal obligation (Article 6(1)(c) GDPR): Some data may be processed to fulfill legal obligations of the Administrator (for example, storing accounting documentation for tax purposes).
• Legitimate interest (Article 6(1)(f) GDPR): Processing data to secure the Service, pursue claims, prevent fraud, or for analytics and statistics is based on our legitimate interest as the Administrator, while ensuring this interest does not override Users' rights and freedoms.

§ 5Sharing data with other entities

We respect Users' privacy and do not sell or share personal data with third parties unless it is necessary to provide our services or required by law. In particular, data may be disclosed to the following categories of recipients:

• Processors (service providers): We may entrust data processing to trusted third-party providers, such as online payment processors, courier companies, hosting providers, or IT service providers necessary for operating the Service. These entities have access to data only to the extent required to perform their services and under agreements that obligate them to protect the data.
• Legal requirements and public authorities: We may disclose User data if required by law or in response to valid requests from authorized public authorities (for example, courts or law enforcement) in accordance with applicable regulations.
• Business transactions: In the event of a merger, acquisition, or sale of all or part of the business, Users' personal data may be transferred to the new entity as part of the continued operation of the Service. Users will be informed about the change of data controller and their rights.

§ 6Transfers outside the EEA

As a rule, we do not transfer Users' personal data outside the European Economic Area (EEA). If, however, the use of external providers (for example, technology providers) involves transferring data to a third country (outside the EEA), we will ensure appropriate safeguards required by law, including standard data protection clauses adopted by the European Commission, so that the transfer respects Users' rights and privacy.

§ 7Data retention period

We store Users' personal data only for the period necessary to achieve the purposes for which it was collected, unless a longer retention period is required by law.

• Data related to account creation and use of the Service is stored for the duration of the User account, and after deletion for the period needed to secure potential claims or fulfill legal obligations (for example, accounting records).
• Data related to transactions (game purchase) is stored for the period required by tax and accounting regulations.
• Data related to activity in the Service (logs, information about game feature usage) may be stored longer for analytics and security improvement, in a form that does not allow identification of the User (for example, after anonymization).

§ 8Data security

We make every effort to protect Users' personal data from unauthorized access, disclosure, alteration, or destruction. We use appropriate organizational and technical measures consistent with industry standards, including encrypted transmission (HTTPS/SSL) and protection of servers and databases. However, no method of data transmission over the Internet or electronic storage is completely secure. While we strive to protect data, we cannot guarantee absolute security.

§ 9User rights

Users whose data we process have the following rights under GDPR:

• Right of access: The right to obtain confirmation of whether we process personal data and, if so, access to it and information about processing purposes, categories, and recipients.
• Right to rectification: The right to correct inaccurate personal data or complete incomplete data.
• Right to erasure: The right to request deletion of personal data (the "right to be forgotten"), subject to cases where processing is still required by law.
• Right to restriction of processing: The right to request temporary restriction of processing in specific situations, such as when the User questions data accuracy or has objected to processing.
• Right to data portability: The right to receive personal data provided by the User in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to object: The right to object to processing based on the Administrator's legitimate interest for reasons related to the User's particular situation. In case of objection, we will stop processing unless we demonstrate compelling legitimate grounds overriding the User's interests, rights, and freedoms, or grounds for establishing, pursuing, or defending claims.
• Right to withdraw consent: If processing is based on consent (for example, newsletter), the User may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the data protection supervisory authority - in Poland, the President of the Personal Data Protection Office (PUODO) - if the User believes their data is processed unlawfully.

To exercise your rights, you can contact us by sending an email to: info@murdermysteryfiles.com. We will respond as soon as possible, no later than within the statutory time limit (generally one month, with a possible extension of up to three months in particularly complex cases, and the User will be informed).

We also inform you that we do not use automated decision-making, including profiling, that would produce legal effects or similarly significant impacts on Users.

§ 10Cookies and local storage policy

Our Service uses cookies and browser local storage to provide the best possible experience and adapt the Service to User preferences.

By using the Service, the User agrees to the use of these technologies as described in this Privacy Policy. More information about cookies is also available in the User's browser settings.

§ 11Changes to this Policy

We may periodically update this Privacy Policy to reflect changes in our practices or legal requirements. The updated version will be published on our website with the updated "last updated" date. We recommend reviewing the Policy regularly. If significant changes are introduced, we may notify Users via the email associated with their account. Continued use of the Service after changes means acceptance of the updated Privacy Policy.

§ 12Contact

If you have questions, comments, or requests regarding this Privacy Policy or the processing of personal data by the Company, please contact: