Privacy Policy

Privacy Policy

(Pursuant to Article 13, 14, et seq.  of 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, ("GDPR"), and §19 et seq, Act of the National Council of the Slovak Republic No. 18/2018, on the protection of personal data and on the amendment and supplementation of certain laws)

This privacy policy was last updated on 26 April 2024.

1. Introduction

1.1 Produced by Laser Focus s. r. o., Homerun – Baseball PVP Game is a mobile game available for iOS and Android, in which users compete as part of a virtual baseball team (“Game”).

1.2 This privacy policy ("Document") describes how our company Laser Focus s. r. o. with its registered office at Budatínska 3230/16A, Bratislava - mestská časť Petržalka 851 06, 900, Company ID: 55 749 275, registered in the Commercial Register of the Municipal Court of Bratislava III, section Sro, entry no. 172759/B (hereinafter referred to as "our Company," "we," "our," or "us") within the scope of its activities within the Game acquires and processes personal data of relevant data subjects.   Our Company acts here as the controller, which means that we have determined the purposes for which we need to acquire or process personal data (e.g., to enter into a valid and effective contract with you).

1.3 When it comes to your personal data, safety and transparency take top priority. The purpose of this Document is therefore to clarify what personal data we acquire and process, why we acquire and process this data, what we do with it, how we protect it and how long we retain it. If you have any questions or concerns about the processing of personal data by our company, you can contact us in writing at the address below or by sending a message to our email address at office@laserfocus.games.

2. What personal data do we process?

We primarily process personal data that you provide to us during the Game. These mainly include, but are not limited to: 

• Identification data (such as: nickname, user id, device id, team name,);

• Game data (such as: activity within the game, relevant wins, loses, relevant awards, progress within the game).

• Payment data (such as: your user id, related payment details).

In addition to this personal data, we may also process relevant personal data of data subjects that provide us our services in relation to the development and operation of the game. These mainly include, but are not limited to: 

• personal data you provide during your supply of services or any other type of collaboration such as: first name, last name, business email address, or any other specific data relevant for further collaboration;

• exceptionally, data provided by authorized third parties or government authorities or obtained from publicly available sources, which we process for the purpose of fulfilling our legal or contractual obligations. In such cases, before obtaining this personal data, we verify whether these entities have a proper legal basis for sharing this data.

Every user has the option to request a complete deletion of this data through this link:: https://laserfocus.games/account-deletion.html

3. Why do we process personal data (what are our purposes) and what is the legal basis for this processing?

Our main goal in processing your personal data is to provide our services within our Game or to secure effective collaboration. To achieve this goal, we process your personal data for the purposes listed below. Each purpose includes a more detailed explanation to help you better understand the activities we perform in the context of each purpose.

Purpose

3.1 Provision of services within the Game

Further description of the purpose: We collect and process personal data here for you to be able to participate in the Game as well as to provide you our services and products within it.  

This includes obtaining the relevant registration information necessary for creating an account, and the relevant activity data based on which we can calculate the relevant results within the game, your progress and evaluate the relevant awards. 

The legal basis for processing under this purpose is:

• the performance of a contract or in order to take steps prior to entering into a contract (Art. 6 (1)(b) GDPR) (here, we rely on the performance of our Terms and Conditions which govern our relationship during the Game) 

• legitimate interests pursued by our Company (Art. 6 (1)(d) GDPR), which are: 

• effective provision of services within the Game,

• effective communication and exchange of information with clients and other partners whose cooperation is necessary for the effective execution of the project.

Therefore, the provision of personal data is mandatory, as otherwise our services could not be provided, and you would not be able to enjoy the entertainment experience of our Game.

3.2 Effective cooperation with our service providers and business partners

Further description of the purpose: We collect and process personal data here in order to secure effective cooperation with the parties that supply our services or other business partners.  These steps are needed in order to conclude the relevant contract and ensure subsequent effective collaboration pursuant to this contract. 

The legal basis for processing under this purpose is:

• performance of a contract or in order to take steps prior to entering into a contract (Art. 6 (1)(b) GDPR),

• legitimate interests pursued by our Company (Art. 6 (1)(d) GDPR), which are: 

• effective project execution,

• effective communication and exchange of information with services providers, business partners or other subjects whose cooperation is necessary for the effective execution of the Game and other relevant tasks 

3.3 External communication of the Company with the public

Further description of the purpose: We collect and process personal data to inform the public about the Game as well as about other activities on our Company's websites.

The legal basis for processing under this purpose is: 

• performance of a contract or in order to take steps prior to entering into a contract (Art. 6 (1)(b) GDPR),

• legitimate interests pursued by our Company (Art. 6 (1)(d) GDPR), which are:

• informing individuals about the Company's activities, external promotion of the Company,

• building a positive reputation and attractiveness of the Company and its representatives in the eyes of the public, public authorities, and business partners.

3.4 Conclusion of employment relationships and internships

Further description of the purpose: We collect and process personal data with the aim of concluding and managing employment relationships, as well as relevant internship contracts.

The legal basis for processing under this purpose is: 

• compliance with a legal obligation to which the controllers is subject (Art. 6(1)(c) GDPR), mainly:

• Act No. 311/2001 Coll. Labor Code,

• Act No. 462/2003 Coll. on Income Replacement During Temporary Incapacity for Work,

• Act No. 580/2004 Coll. on Health Insurance,

• Act No. 461/2003 Coll. on Social Insurance,

• Act No. 650/2004 Coll. on Supplementary Pension Savings,

• Act No. 563/2009 Coll. on Tax Administration (Tax Code),

• Act No. 595/2003 Coll. on Income Tax.

• performance of a contract or in order to take steps prior to entering into a contract (Art. 6 (1)(b) GDPR),

• legitimate interests pursued by our Company (Art. 6 (1)(d) GDPR), which are:

• effective and reliable performance of the Company's internal activities.

3.5 Addressing individual inquiries via e-mail or registered mail. 

Further description of the purpose: We collect and process personal data for the purpose of responding to communications received via email or registered mail. 

The legal basis for processing under this purpose is:

• legitimate interests pursued by our Company (Art. 6 (1)(d) GDPR), which are:

• effective and reliable performance of the Company's internal activities.

3.6 General compliance of Company’s activities with relevant legal obligations as well as the responsible Company behaviour

Further description of the purpose: We collect and process personal data here in order to ensure the fulfilment of our obligations in the field of:

• Company's business matters,

• Labor and employment relationships,

• Personal data protection,

• Payroll and tax matters, as well as related contribution obligations,

• Protection against money laundering and compliance with international sanctions.

The legal basis for processing under this purpose is: 

• compliance with a legal obligation to which the controllers is subject (Art. 6(1)(c) GDPR), mainly:

• Act No. 311/2001 Coll. Labor Code,

• Act No. 513/1991 Coll. Commercial Code,

• Act No. 297/2008 Coll. on the prevention of money laundering and the prevention of terrorist financing,

• Act No. 289/2016 Coll. on the implementation of international sanctions,

• Act No. 18/2018 Coll. on the protection of personal data,

• Act No. 462/2003 Coll. on the compensation of income during temporary incapacity for work,

• Act No. 580/2004 Coll. on health insurance,

• Act No. 461/2003 Coll. on social insurance,

• Act No. 650/2004 Coll. on supplementary pension savings,

• Act No. 563/2009 Coll. on tax administration (Tax Code),

• Act No. 595/2003 Coll. on income tax.,

• Legitimate interests pursued by our Company (6 (1)(f) GDPR), which are:

• effective risk assessment to prevent the provision of services and the establishment of relationships with prohibited and/or sanctioned individuals, efficient fulfilment of our Company's obligations in money laundering prevention and fraud,

• efficient and reliable performance of the Company's internal activities.

4. From where do we obtain personal data?

In most cases, as outlined above, we obtain personal data directly from you. In exceptional cases, we may also obtain your personal data from other entities, primarily:

• From contractual parties who have provided your personal data as part of a collaboration or supply of services;

• From other individuals who contact us by mail or email and provide your personal data.

5. How Long Do We Retain Personal Data?

Our criteria for determining the retention period of personal data are as follows: Personal data is retained for the entire period of its use for the purposes mentioned above. Personal data may occasionally be retained for an additional period until all of our claims under a contract or other form of cooperation have expired. Exceptionally, personal data may be retained for a further extended period as required by applicable legal regulations (e.g., as part of obligations to retain and process financial or accounting information).

6. Do we process personal data based on your consent?

As of the date of this Document, no. While we cannot exclude the possibility that in the future, it may be necessary to request your consent to obtain and process specific personal data in such cases we will always ask you in advance for specific and informed consent for the processing in question. You will also have the option to withdraw your consent at any time.

7. Do we share personal data? (and who are their recipients?)

We will only share your personal data with third parties if it is necessary to properly secure the services we provide to you, or if you have given us consent to share your personal data, or if we do so for legal reasons, based on a court order, or if we are required to do so by another official authority.

In such cases your data will only be disclosed to the following categories of recipients:

1. • 1. On a "need to know basis" to our employees or interns whose employment contract or internship agreement with us binds them to confidentiality obligations.

     2. To third parties who assist us in providing our services in accordance with our contractual terms, including but not limited to development service providers, marketing service providers, and payment services. Please note relevant links to their privacy policies which further explain how the personal data are used: Google Play Services, AdMob, Ironsource, Google Analytics for Firebase, Firebase Crashlytics, Facebook, Unity

     3. To state authorities, if required within the scope of the relevant cooperation. 

7.1 Do we transfer personal data outside the European Economic Area ("EEA")? 

For the purposes of providing our services it may be sometimes necessary to transfer personal data outside of EEA, currently to the United States of America.

Here we make sure that there are appropriate data protection measures in place which meet GDPR data protection standards. Specifically, in our transfers to the United States of America we rely on the Data Privacy Network approved by the European Commission with the decision on Data Privacy Network. 

If we were to decide to transfer such data outside the EEA in the future, we would not do so unless appropriate data protection security measures meeting GDPR data protection standards (e.g., an adequacy decision in the respective country or the implementation of standard contractual clauses of the European Commission in our contracts with entities in these third countries) are in place.

8. Are personal data safe with us?

We take security in all areas very seriously and have committed to maintaining the highest standards of personal data security. We strive to design our data security principles and processes in line with data security and ensure that all our employees and interns adhere to them to prevent unauthorized or unlawful processing, accidental loss, destruction, or damage to your data.

In the interest of protection, we have implemented necessary security measures (technical, organizational, and others) and established processes to monitor their compliance and effectiveness.

We process personal data only within the necessary timeframe to fulfil the relevant purpose for which they are processed. The processing duration and any subsequent retention of personal data are determined by either applicable regulations, laws, or other binding regulations, our internal regulations, or operational needs and legitimate interests pursued in the respective processing.

9. Do we carry out automated decision-making or profiling?

No.

10. What rights do you have in connection with the personal data?

In connection with the processing of personal data, you have the following legal rights. In addition, you can also revoke any consent you have given for data processing at any time, and you have the right to lodge a complaint with the supervisory authority. Your rights in connection with the personal data you provide to us are explained in more detail below, and you can exercise them by emailing us at office@laserfocus.games.

Right of access
You can request clear and transparent information about whether and how we process your personal data.

Right of rectification
We strive to ensure that your personal data is accurate and up to date. You have the right to request the correction of any incorrect data or the completion of any incomplete data.

Right of erasure („right to be forgotten “)
Upon your request, we will delete your personal data that we process about you.

Right to restriction of processing
In certain cases and for legitimate reasons, you can request the limitation of the processing of your personal data, which will permanently or temporarily restrict our ability to use your personal data without deleting them.

Right to data portability
Upon your request, you will receive an electronic copy of the personal data you provided to us during registration. If technically feasible, this copy can also be transferred to another entity.

Right to object
If the processing of your personal data is based on our legitimate interest, you can object to this processing at any time.

Right to lodge a complaint

If you have doubts about the processing of personal data, you can contact us by email at office@laserfocus.games. In addition to the above-mentioned rights, you can also file a direct complaint about the processing and protection of your personal data with our Company at the Slovak Office for Personal Data Protection.

We continuously verify the accuracy and completeness of the information provided in this Document. This Document was last updated on 26 April, 2024. For information about changes compared to the previous version, please contact us at the email address office@laserfocus.games.