I. How do we obtain your personal data?

We obtain your personal data in various ways, only with your consent. We treat your consent as your completion and submission of a form containing personal data or sending an e-mail containing your personal data in any form. We obtain your data directly, using our websites or e-mail system and using external systems used for employee recruitment.

Whistleblower Report Form
Filling out the form on the website means that the data provided in it, including personal data, will be processed in order to process your report and provide an answer to it.

Contact Form
If your question refers to our services, we may present you with an offer in response. Filling out the form means that the personal data provided in it will be processed in order to establish contact and present the offer. You can find the principles of processing and information about the administrator here.

Sharing data for recruitment purposes
By participating in the recruitment process, you agree to the processing of your personal data, so please familiarize yourself with the principles of personal data processing applicable at Roboto Global Sp. z o.o.

II. Your rights regarding personal data

You have the right to obtain from the controller confirmation as to whether personal data concerning you are being processed and, if so, you are entitled to access them and obtain the following information:

• the purpose of processing the personal data;
• the categories of personal data concerned;
• information on the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the planned period for which the personal data will be stored and, if this is not possible, the criteria for determining this period;
• information on the right to request the controller to rectify, erase or restrict the processing of personal data concerning the data subject and to object to such processing;
• information on the right to lodge a complaint with a supervisory authority;
• if the personal data have not been collected from the data subject, any available information on their source;
• information on automated decision-making, including profiling, as referred to in Article 22 para. 1 and 4, and – at least in those cases – meaningful information on the principles governing their adoption, as well as on the significance and envisaged consequences of such processing for the data subject.

Where personal data are transferred to a third country or an international organisation, the data subject shall have the right to be informed of the appropriate safeguards referred to in Article 46 relating to the transfer.

The controller shall provide the data subject with a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. If the data subject requests a copy by electronic means and unless the data subject indicates otherwise, the information shall be provided in a commonly used electronic form.

I. Introduction

This policy describes the types of information Think Tank Media, LLC or Roboto Global, LLC or Robo Toro Games, LLC (the “Company,” “we,” “our,” or “us”) may collect from you or that you may provide when you visit the websites https://www.roboto.pl, https://www.roboto.global, https://www.robotorogames.com, https://www.robotoro.games (“Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company or a third party or through any application or content (including advertising) that may link to or be accessible from the Website.

The Company is committed to protecting your privacy. We provide this policy to explain the type of information we collect and to inform you of the specific practices and guidelines that protect the security and confidentiality of your personal data. Please read this policy carefully. If any term in this policy is unacceptable to you, please do not use the Website or provide any personal data. This policy may change from time to time.

II. Information we collect about You and how we collect it

We collect several types of information from and about users of our Website, which may include information defined as personal data under the General Data Protection Regulation (“personal data”). For example, we may collect information such as your name, e-mail address, telephone number, job function, company/organization name, file uploads by you, and information related to inquiries and requests. We may also collect bank account information and bank account and routing information. We may also collect information about your internet connection and the equipment you use to access our Website. As you navigate through the Website, we may automatically collect information such as your usage details, IP addresses, and information collected through cookies.

1. Information You Give to Us

The information we collect on or through our Websites may include:

• Information that you provide by filling in forms on our Websites. This includes information provided when you sign up for newsletters, blog subscriptions and other types of information material; when we process and respond to your inquiries related to products and customer service; and when you provide feedback on our Websites. The personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal data.
• Records and copies of your correspondence with us (including email addresses)

2. Information We Collect About You

As with many other websites, as you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Websites, including resources (e.g. videos and PDFs) that you access, download and use on our Websites, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.
• Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.
• Details of referring websites (URL).

The information we collect automatically is statistical data that helps us improve our Websites and deliver a better and more personalized service, including by enabling us to

• Determine web site traffic patterns.
• Count web visits.
• Determine traffic sources so we can measure and improve the performance of our site.
• Help us to know which pages and content are the most and least popular.
• Observe site search patterns to provide more intuitive navigation cues.
• Determine user frequency.

3. Google Analytics

Our Websites may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the Website analyze how users use the Website. The information generated by the cookie about your use of the Website will be transmitted to and stored by Google on servers in the United States.

Google will use this information on behalf of us as the operator of this Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to us.

In case IP anonymization is activated on our Websites, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the United States and truncated there. The IP anonymization is active on Websites.

The IP address, that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our Websites.

You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser.

4. Cookies Used on This Website

Our Websites use single-session (temporary) and multi-session (persistent) cookies. Temporary cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation on our Websites. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our site and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. Cookies, by themselves, will not be used by the Company to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Website. If you want to disable the use of cookies or remove them at any time from your computer, you can disable or delete them using your browser (consult your browser’s “Help” menu to learn how to delete cookies); however, you must enable cookies to access certain information on our Websites.

III. How we use your information

Below please find information about how we process information collected about you (including personal data) as well as the corresponding legal basis. We may process your information where the processing is:

• Necessary for entering into or the performance of a contract with you. For example:
  • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us.
  • To process your job application.
  • Necessary for us to comply with a legal obligation.
• Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:
  • To ensure that content from our Website is presented in the most effective manner for you and for your computer.
  • To allow you to participate in interactive features of our service (when you choose to do so).
  • To keep our Website safe and secure.
  • To provide you with technical support and to improve our Website and services.
  • To provide you with information that you have requested and respond to your inquiries.
  • To notify you about changes to our service or our Website.
  • If you are an existing customer, to communicate (including by email and SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
  • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us.
• Pursuant to valid consent provided by you, in order to provide you with information about goods or services we feel may interest you. If you do not want us to use your data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data or unsubscribe by sending your request to .
• For any other purpose where you have provided valid consent where it is legally required.

IV. Disclosure of your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Subject to applicable law and regulations, we may disclose personal data that we collect or you provide as described in this policy:

• To any member of our group, which means our affiliates and subsidiaries for the purposes of:
  • Carrying out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us.
  • Processing your job application.
  • Providing you with information that you have requested and responding to your inquiries.
    If you are an existing customer, communicating (including by email and SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
  • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us.
• To contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the activities noted above and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them (e.g., database hosting providers, payment providers, managed services providers, developers, consultants; service providers assisting us with customer relationship management, content development and management as well as facilitating the upload of documents provided by you through our Website). User PII information (name, email address and bank account information) collected will be shared to Dwolla, Inc., or other payment partners, to facilitate payments to accounts. If you have any questions or concerns about a service provider or partner, please contact us at .
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you email us asking us to contact a third party, we may transmit the contents of your email to the recipient.
• For any other purpose disclosed by us when you provide your information or with your consent when required by applicable law and regulations.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of the Company, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at .

V. Data Retention

Unless otherwise required by law, the Company will erase personal data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal data has been unlawfully processed; and when it is necessary to comply with legal obligations.

V. Data Retention

Unless otherwise required by law, the Company will erase personal data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal data has been unlawfully processed; and when it is necessary to comply with legal obligations.

VI. Your Rights with Regard to Your Personal Data

We remind you that you may at any time exercise certain rights you may have under applicable law and regulation, including the following rights:

• The right to request access to your personal data, which includes the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and information related to how it is processed.
• The right to rectification or erasure of your personal data, which includes the right to have incomplete personal data completed, including by means of providing a supplementary statement, and certain rights to request us to erase your personal data without undue delay.
• The right to restrict or object to processing concerning your personal data, which includes restricting us from continuing to process your personal data under certain circumstances (e.g., where you contest the accuracy of your personal data, processing is unlawful, your personal data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making).
• The right to data portability, which includes certain rights to have your personal data transmitted from us to another controller.
• Where data processing is based on your consent, the right to withdraw consent at any time.
• The right to lodge a complaint with a supervisory authority.

VII. Data Security

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal data provided to us in accordance with this policy will be encrypted in transit and at rest.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission of your personal data is at your own risk.

VIII. Third-Party Websites

Our Website may contain links or references to other websites outside of our control. Please be aware that this policy does not apply to these websites. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data. THE COMPANY DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

IX. Data Controller & Contact Information

The data controller is: Roboto Global Sp. z o.o., ul. Gdańska 41, 01-633 Warszawa, Poland

Should you have any questions or concerns about this policy and our privacy practices our Data Protection Officer can be contacted at .