PRIVACY POLICY

GENERAL INFORMATION

The purpose of the Privacy Policy is to provide information regarding the processing of personal data in connection with the activities conducted by inStreamly. Whenever the Privacy Policy uses the term:

inStreamly	means the company inStreamly P.S.A. with its registered office in Warsaw, address: ul. Lindleya 16, 02-013 Warsaw, entered in the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number: 0000953481, NIP: 7010954779, with share capital of PLN 64,000.00 (in words: sixty-four thousand 00/100) zlotys;
GDPR	means 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
Website	means the website operated by inStreamly at: https://newgameplus.group/.

The Privacy Policy defines how inStreamly uses the personal data of users who visit websites operated by inStreamly, interact with it, and use the services available on inStreamly's websites.

In case of any questions or desire to exercise privacy rights (in accordance with section 19 of the Privacy Policy), please follow the instructions contained in the Privacy Policy.

LINKS OUTSIDE THE WEBSITE

The Website may lead (link) to other websites, including websites of entities not affiliated with inStreamly, in particular to social media portals. The rules regarding the processing of personal data on these sites are governed by their providers.

DATA CONTROLLER

The data controller is inStreamly, i.e., inStreamly P.S.A. with its registered office in Warsaw, address: ul. Lindleya 16, 02-013 Warsaw, entered in the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number: 0000953481, NIP: 7010954779, with share capital of PLN 64,000.00 (in words: sixty-four thousand 00/100) zlotys.

CONTACT WITH THE DATA CONTROLLER

You can contact inStreamly in the following ways:

via the contact form available on the Website;
by email, sending a message to: kontakt@newgameplus.group;

In all matters concerning the processing of personal data by inStreamly, you can contact them by email at kontakt@newgameplus.group.

DATA COLLECTION, PURPOSE AND LEGAL BASIS FOR PROCESSING

Depending on the form of interaction, inStreamly may collect various data, including personal data.

inStreamly's Contractors	inStreamly collects data in connection with the provision of services, as well as in connection with services provided to inStreamly by its contractors. Data collection applies to current and future contractors of inStreamly.
	This data may include: name, surname, email address, telephone number, tax identification number and other registry numbers in which the contractor appears, business address, bank account number. Depending on the circumstances and the contractor's person, the scope of data may vary, which the contractor is informed about by inStreamly.
	inStreamly processes this data for the purposes of: taking steps at the request of the contractor before concluding a contract (e.g., presenting an offer regarding inStreamly's services) (Art. 6(1)(b) GDPR); concluding and performing a contract by inStreamly (Art. 6(1)(b) GDPR); fulfilling tax and legal obligations (Art. 6(1)(c) GDPR); pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims, maintaining ongoing relations with contractors within the framework of cooperation, verifying contractors, as well as making internal settlements (Art. 6(1)(f) GDPR).
	Data is collected directly from inStreamly's contractors. Providing data is voluntary, however, the lack of some of it may result in the impossibility or refusal to conclude or perform a contract, and in cases provided by law, also its termination. Data may also be collected using public registers such as the Court and Business Monitor, National Court Register or Central Register and Information on Business Activity, Central Register of Beneficial Owners or other national and foreign registers relevant to the client or contractor.
	Data is stored for a period of three (3) years (from the end of the calendar year in which the data was obtained) from the date of contract implementation or its termination. However, data contained in settlement documents is stored for a period of five (5) years (from the end of the calendar year). These periods may be extended in case of pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims.
Representatives and Staff of Contractors	inStreamly collects data in connection with the provision of services, as well as in connection with services provided to inStreamly by its contractors. Data collection applies to current and future representatives and staff of inStreamly's contractors. This includes persons who are holders of statutory bodies, proxies and attorneys, employees and collaborators of the contractor participating in the conclusion and execution of a contract with inStreamly, as well as data of third parties who perform activities related to the conclusion and participation in the execution of a contract with inStreamly on behalf of the contractor (e.g., legal advisors, accountants).
	This data may include: name, surname, email address, telephone number, tax identification number and other registry numbers in which the representative or staff of the contractor appears, business address, bank account number. For holders of statutory bodies and proxies: PESEL number. Depending on the circumstances and the contractor's person, the scope of data may vary, which the contractor is informed about by inStreamly.
	inStreamly processes this data for the purposes of: contact in connection with the conclusion or performance of a contract with the contractor (Art. 6(1)(f) GDPR); pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims, maintaining ongoing relations with contractors within the framework of cooperation, verifying contractors, as well as making internal settlements (Art. 6(1)(f) GDPR); fulfilling tax and legal obligations (Art. 6(1)(c) GDPR).
	Data is collected directly from the persons concerned or from other sources, including from inStreamly's contractors. Providing data is voluntary, however, the lack of some of it may result in the impossibility or refusal to conclude or perform a contract, and in cases provided by law, also its termination. Data may also be collected using public registers such as the Court and Business Monitor, National Court Register or Central Register and Information on Business Activity, Central Register of Beneficial Owners or other national and foreign registers relevant to the client or contractor.
	Data is stored for the period of communication, and after that time for a period of three (3) years (from the end of the calendar year) from the date of contract implementation or its termination. However, data contained in settlement documents is stored for a period of five (5) years (from the end of the calendar year). These periods may be extended in case of pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims.
Users Contacting inStreamly	inStreamly collects data in connection with user interactions with inStreamly undertaken by email, mail, and through contact forms on the Website. The role of these contacts varies, including the receipt of commercial information from inStreamly. Depending on the role of the contact and in the case of forms with several purposes (e.g., contact and newsletter subscription), inStreamly provides relevant information regarding the collected data and allows the selection of the scope of data processing.
	This data may include: name, surname, email address, affiliation (company represented by the person) and data provided in the message directed to inStreamly. Depending on the circumstances and the contractor's person, the scope of data may vary, which the contractor is informed about by inStreamly.
	inStreamly processes this data for the purposes of: sending email messages containing commercial offers (one-time contact regarding an offer) or commercial information from inStreamly (Art. 6(1)(a) GDPR); contacting the user and considering the matter reported by the user (Art. 6(1)(f) GDPR); in some cases, pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims (Art. 6(1)(f) GDPR).
	Data is collected directly from the persons concerned. Providing data is voluntary, however, the lack of some of it may result in the impossibility of providing a response or considering the matter reported by the user.
	Data is stored for the period resulting from the purpose of its processing and taking into account the purpose of the report. Usually, this period is six (6) months. This period may be extended in case of pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims. In the case of processing data based on consent, data is stored until the consent is withdrawn. After withdrawing consent, data may be processed in case of pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims, for the period of existence of this interest.
Persons Subscribing to Advertising Newsletters	inStreamly collects data in connection with user subscriptions to advertising newsletters allowing receipt of email messages containing commercial information from inStreamly and third parties (advertisers).
	This data usually includes only the email address. However, the person concerned may leave a wider range of data: name, surname, email address, affiliation (company represented by the person).
	inStreamly processes this data for the purposes of: sending email messages containing commercial offers (one-time contact regarding an offer) or commercial information from inStreamly and third parties (advertisers) (advertising newsletter) (Art. 6(1)(a) GDPR); fulfilling legal obligations (showing registration in the database) (Art. 6(1)(c) GDPR); in some cases, pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims (Art. 6(1)(f) GDPR).
	Data is collected directly from the persons concerned. Providing data is voluntary, however, the lack of some of it may result in the impossibility of sending email messages containing commercial information from inStreamly and third parties (advertisers).
	Data is stored until the consent is withdrawn. After withdrawing consent, data may be processed in case of pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims, for the period of existence of this interest.
Persons Interacting with Company Profile on Social Media	inStreamly collects data in connection with its company profiles on social media platforms. These platforms include: Facebook (Meta), Twitter (X), LinkedIn, Instagram, YouTube, TikTok. inStreamly processes personal data of service users visiting inStreamly's profile, service users following the profile, and service users publishing comments on content posted on it within inStreamly's profile or otherwise interacting with inStreamly's profile.
	This data includes: data provided by the user during interaction with inStreamly's profile. Additionally, inStreamly obtains data from the operator of the service, including data that may include: user identifier, name and surname, content of comments published within inStreamly's profile.
	inStreamly processes this data for the purposes of: operating inStreamly's profile within the service (Art. 6(1)(f) GDPR); informing about inStreamly's activities (Art. 6(1)(f) GDPR); responding to comments published by users of the service (Art. 6(1)(f) GDPR); conducting analyses and statistics regarding the operation and manner of use of inStreamly's profile by users (Art. 6(1)(f) GDPR); in some cases, pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims (Art. 6(1)(f) GDPR).
	Data is collected directly from the persons concerned and through the functionalities of the service. Providing data is voluntary, however, the lack of some of it may result in the user's inability to fully use the functionalities located in inStreamly's profile.
	Data is stored for the period determined by the social media platform.
Persons Interacting with inStreamly in Connection with Recruitment	inStreamly collects data in connection with its recruitment processes. Data collection applies to current and future employees of inStreamly.
	This data includes: data provided during the recruitment process (including data contained in CV, cover letter or correspondence regarding recruitment). In case of providing data for which there is no obligation to submit to inStreamly or entitlement to request their provision by inStreamly, inStreamly considers this as consent to process this data for recruitment purposes, which is voluntary and can be withdrawn at any time.
	inStreamly processes this data for the purposes of: fulfilling obligations arising from labor law provisions related to the employment process, in case the intended form of employment is an employment contract (Art. 22¹ § 1 points 1-6 of the Labor Code in connection with Art. 6(1)(c) GDPR or Art. 22¹ § 1 points 1-3 of the Labor Code in connection with Art. 6(1)(c) GDPR); conducting the recruitment process, in case the intended form of employment is a civil law contract (Art. 6(1)(b) GDPR); checking the candidate's knowledge, abilities and skills (Art. 6(1)(f) GDPR); in some cases, pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims (Art. 6(1)(f) GDPR).
	inStreamly will also process personal data in subsequent recruitments if these persons have consented to this (Art. 6(1)(a) GDPR). This consent is voluntary and can be withdrawn at any time.
	Data is collected directly from the persons concerned. Providing data is voluntary, however, in case of intention to employ on an employment contract, failure to provide data specified in Art. 22¹ § 1 of the Labor Code will result in the inability to consider the candidacy.
	Data will be stored for the duration of recruitment for the position to which the application relates. To the extent that the candidate's personal data is processed on the basis of consent given by the candidate to participate in subsequent recruitments, data is stored until the consent is withdrawn or for a period of twelve (12) months, whichever occurs first. The storage period may be extended in case of pursuing legitimate interests of inStreamly, including establishing, pursuing and defending against possible claims.

inStreamly also collects, shares and uses aggregated data (statistical or demographic data), which, however, does not constitute personal data. If this data is combined with data enabling user identification, then aggregated data is treated by inStreamly as personal data.

RIGHTS OF DATA SUBJECTS

The data subject (user) has the following rights:

Right of Access, Rectification, Restriction, Erasure or Portability	The data subject has the right to request from inStreamly access to their personal data, their rectification, erasure ("right to be forgotten") or restriction of processing, and has the right to object to processing, as well as the right to data portability. Detailed conditions for exercising the above-mentioned rights are indicated in Articles 15-21 of the GDPR Regulation.
Right to Withdraw Consent at Any Time	A person whose data is processed by inStreamly on the basis of expressed consent (based on Art. 6(1)(a) or Art. 9(2)(a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint with a Supervisory Authority	A person whose data is processed by inStreamly has the right to lodge a complaint with a supervisory authority in the manner and mode specified in the provisions of the GDPR Regulation and Polish law, in particular the Act on the Protection of Personal Data. The supervisory authority in Poland is the President of the Personal Data Protection Office.
Right to Object	The data subject has the right to object at any time - for reasons related to their particular situation - to the processing of personal data concerning them based on Art. 6(1)(e) (public interest or tasks) or (f) (legitimate interest), including profiling based on these provisions. In such a case, inStreamly may no longer process this personal data unless it demonstrates compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject, or grounds for establishing, exercising or defending legal claims.
Right to Object Regarding Direct Marketing	If personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing purposes, to the extent that processing is related to such direct marketing.

Exercise of the rights of the data subject takes place through contact with inStreamly, and contact details are specified at the beginning of the policy.

DATA TRANSFER

Data collected by inStreamly is generally not transferred to third parties. However, inStreamly may:

transfer data to entities supporting inStreamly in conducting business, such as providers of cloud tools for business operations (e.g., Google Workspace), legal service providers or accounting service providers;
transfer data to law enforcement authorities, supervisory authorities, entities performing public tasks or others, when the obligation to disclose data results from legal provisions.

Data recipients may also be inStreamly's employees and collaborators, hosting providers, marketing and advertising agencies, entities providing IT system service and maintenance. Disclosure or transfer of data must always take place on the basis of a legal provision or appropriate agreement (e.g., entrustment of personal data processing).

Data may be transferred outside the European Economic Area, however, inStreamly ensures that appropriate security measures are provided, i.e., appropriate safeguards and binding corporate rules in accordance with Art. 46 and Art. 47 GDPR. In particular, inStreamly concludes appropriate agreements (standard contractual clauses; provided that the receiving entity guarantees an appropriate level of data security) to secure the transferred personal data and transfers data to countries for which the European Commission has issued a decision establishing an adequate level of protection.

RIGHT TO PRIVACY (RIGHT TO BE FORGOTTEN)

Each user has the right to request the deletion of data held by inStreamly about them. To delete this data, contact inStreamly in accordance with the data in section 6 or 7 of the Privacy Policy.

COOKIES

In order for the Website to function properly, adapt its operation, improve it, and also to conduct advertising activities for its services (e.g., remarketing), inStreamly uses cookies on the Website. Cookies are files sent by the Website stored on the user's device (in the memory of their browser). When the user's device reconnects to the Website or the user uses pages where inStreamly publishes advertisements for its services, the website recognizes the type of device from which the user is connecting.

Cookies collect various data related to the user's use of the Websites, including: IP address, information about the web browser and IT system used by the user. A detailed description of inStreamly's cookies is placed below, as well as in the window displayed to the user during the first visit to the Website or after deleting files on a given device. Limiting the use of cookies (disabling them, restricting them) may affect some functionalities available on the Website and hinder their operation.

The use of cookies other than necessary requires the user's consent. Such consent is voluntary. The user can at any time change or withdraw expressed consent or modify their decision regarding cookies by clicking the "XXX" button placed at the bottom of the Page.