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§ 1. Personal Data Administrator
The Personal Data Administrator (ADO) is the Administration of the "Sejm Roleplay" server. In all matters relating to the processing of personal data and the exercise of rights related to their processing, you can contact us via a dedicated support channel (ticket) on the Discord server or at the e-mail address: [email protected].
§ 2. Purposes and Legal Basis of Data Processing
Users' personal data are processed in a lawful manner, based on the following legal bases and for the purposes listed below: 1. In order to provide the Service (contract for the provision of electronic services, which are the Terms of Use) - legal basis: Art. 6 section 1 letter b GDPR: • Managing the User account on the Discord server (assigning roles, identification, authorization). • Linking your Discord account to your Roblox account to verify and sync permissions. • Allowing participation in roleplay through the processing of IC profile data. • Conducting votes and elections within the server mechanics. 2. In order to implement the legitimate interest of the Administrator - legal basis: Art. 6 section 1 letter f GDPR: • Maintaining statistics of Users' activity in order to evaluate and improve the functioning of the Services. • Conducting moderation activities, including enforcing server regulations (imposing penalties, keeping records). • Establishing, pursuing or defending possible claims.
§ 3. Scope of Processed Data
As part of the provision of Services, the Administrator processes the following categories of personal data: 1. Discord account details: • User ID (Discord User ID) • Username, tag, server nickname (nickname) • Roles assigned on the server 2. Roblox account details (linked by the User): • Roblox User ID (Roblox ID) • Account name (Username) • Rank in related Roblox groups 3. IC (In-Character) profile data: Fictitious data created by the User for the purposes of the game, such as the character's name and surname, date of birth, residential address, etc. 4. Activity data: Daily number of messages, time spent on voice channels. 5. Voting data: Information about voting participation, vote cast, User ID and timestamp. 6. Moderation data: History of imposed penalties and administrative actions.
§ 4. Data Recipients and Data Transfer Outside the EEA
1. Users' data may be entrusted for processing to third parties that provide the Administrator with technical services necessary for the operation of the server (so-called data processors). These include: • Discord Inc. (communication platform provider) • Roblox Corporation (gaming platform and authorization system provider) • Database hosting providers: Supabase Inc. 2. Due to the fact that the listed suppliers are based mainly in the United States, Users' personal data may be transferred outside the European Economic Area (EEA). This transfer is carried out ensuring an appropriate level of protection, mainly on the basis of standard contractual clauses approved by the European Commission, which guarantee that the data will be protected in accordance with the requirements of the GDPR.
§ 5. Data Storage Period (Retention)
Users' personal data are stored for the period necessary to achieve the purposes for which they were collected: 1. Verification and profile data (Discord ID, Roblox ID, IC profile): Throughout the period of the User's active participation on the server. This data is deleted or anonymized immediately after receiving a request to delete the account or after the User leaves the server. 2. Activity data: They are stored for a maximum of 15 days, after which they are automatically deleted. 3. Data regarding voting and moderation history: They are stored for the period necessary to maintain the integrity and history of the server, but no longer than until the User deletes his account or requests their deletion, unless other legitimate purposes prevent this (e.g. defense against claims).
§ 6. Rights of Data Subjects
In connection with the processing of personal data, each User has the following rights: • The right to access data (Article 15 of the GDPR): The right to obtain from the Administrator confirmation whether his personal data is being processed, and if so, he is entitled to access them and the information specified in Art. 15 GDPR. • The right to rectify data (Article 16 of the GDPR): The right to request the Administrator to immediately correct inaccurate personal data concerning him. • The right to delete data, "the right to be forgotten" (Article 17 of the GDPR): The right to request the Administrator to immediately delete your personal data if one of the circumstances indicated in Art. 17 section 1 GDPR. • The right to limit processing (Article 18 of the GDPR): The right to request the Administrator to limit processing in the cases indicated in Art. 18 section 1 GDPR. • The right to data portability (Article 20 of the GDPR): The right to receive personal data provided to the Administrator in a structured, commonly used and machine-readable format and the right to send this data to another administrator. • Right to object (Article 21 of the GDPR): The right to object at any time - for reasons related to your particular situation - to the processing of your personal data based on a legitimate interest (Article 6(1)(f) of the GDPR). • The right to lodge a complaint with the supervisory authority: If it is considered that the processing of personal data violates the provisions of the GDPR, the User has the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Office for Personal Data Protection (address: ul. Stawki 2, 00-193 Warsaw). In order to exercise the above rights, please contact the Administrator via the communication channels indicated in § 1.
§ 7. Data Security
The Administrator declares that he applies appropriate technical and organizational measures to ensure the protection of processed personal data. In particular: • Only authorized persons have access to the data and only to the extent necessary to perform their tasks. • Databases are protected against unauthorized access.
§ 8. Automated Decision Making
Users' data are not subject to automated decision-making that would have legal effects on them. Activities such as automatic role assignment or activity statistics are of a technical and organizational nature, and any moderation decisions (e.g. imposing a penalty) are made or verified by members of the Administration.
§ 9. Final Provisions
1. The Administrator reserves the right to make changes to this Privacy Policy. Users will be informed about any changes in advance on the Discord server. 2. In matters not regulated in this Privacy Policy, the relevant provisions of law shall apply, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).