Polityka prywatności

Current Games B.V. ("Current Games", "we", "us", or "our") operates the website Current.games ("Website") and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your data when you use the Website, purchase digital activation keys, gift cards, downloadable content (DLC), or top-ups, or engage with our services. As a Dutch company (KvK 95626271), we act as the data controller under the General Data Protection Regulation (GDPR) for EU users and comply with the California Consumer Privacy Act (CCPA) for California residents.

This policy applies to consumers ("you") and forms part of our Terms of Service. Third-party platforms (e.g., Steam, PlayStation, Xbox) have separate policies; please review them independently. By using the Website, you consent to the practices described herein.

1. Data We Collect

We collect personal data to provide and improve our services, categorized as follows:

• Identity and Contact Data: Name, email address, billing address, phone number, and date of birth (for age verification of 18+ products).
• Financial and Transaction Data: Payment information (processed via Xsolla), order history, and redeemed keys/DLC.
• Technical Data: IP address, device type, browser, location (for region-locked keys and fraud detection), and operating system.
• Usage Data: Browsing activity, search terms (e.g., game titles), and interactions with wishlists or downloads.
• Marketing Data: Preferences for newsletters or personalized offers.

We do not collect sensitive data (e.g., health, biometrics) or criminal records. For users under 18, parental consent is required per our Terms.

Sources:

• Directly from you: Account registration, checkout, or support inquiries.
• Automatically: Cookies, pixels (Google Analytics, TikTok Pixel, Facebook Pixel), and server logs.
• Third parties: Xsolla (payments and fraud detection), Avrix (key legitimacy verification), and gaming platforms (e.g., Steam for activation confirmations).

2. How We Use Your Data

We process data under GDPR Art. 6 (contract performance, legitimate interests, or consent) and CCPA (business purposes) for the following purposes:

• Order Fulfillment: Process payments, deliver keys via email or account dashboard, and verify region compatibility (e.g., IP or billing address checks).
• Account Management: Maintain user profiles, wishlists, order history, and perform manual age verification for PEGI 18+ products.
• Support and Security: Address inquiries, prevent fraud (e.g., Xsolla's IP-based checks), and resolve activation issues.
• Analytics: Improve Website performance using Google Analytics (anonymized, no individual profiling).
• Marketing: Deliver newsletters or personalized offers (e.g., DLC promotions) with your consent.
• Legal Compliance: Meet tax, VAT, PEGI, or fraud prevention obligations.

Gaming-specific: Data ensures key activation on platforms (e.g., Xbox) and compliance with regional requirements (e.g., EU VAT).

Retention: Transaction data is retained for 7 years (Dutch tax law), analytics data for 14 months, and other data until account deletion plus 30 days.

3. Data Sharing

We share data only as necessary, with appropriate safeguards (GDPR Art. 28):

• Service Providers: Xsolla (payments and fraud detection), Tencent Cloud (hosting), Google (analytics, anonymized), TikTok/Meta (marketing pixels, consent-based), and Mailchimp (newsletters, if implemented).
• Partners: Avrix (key authenticity verification), publishers (e.g., for activation data or anonymized trends).
• Legal/Affiliates: Authorities (e.g., for tax compliance), group companies, or during mergers (with prior notice).
• No Data Sales: We do not sell personal data (CCPA "sale" opt-out not applicable).

International transfers to the US (Xsolla, Google, TikTok, Meta) or China (Tencent Cloud) are protected by Standard Contractual Clauses (SCCs). A Data Processing Addendum is available on request via support@current.games.

4. Your Rights

Under GDPR and CCPA, you have the following rights (exercised free of charge, within 1 month, with identity verification):

• Access: Obtain a copy of your personal data.
• Correction/Erasure: Rectify inaccuracies or request deletion (subject to legal retention, e.g., tax records).
• Restriction/Objection: Restrict processing (e.g., marketing) or object to legitimate interest processing.
• Portability: Receive data in a machine-readable format (e.g., order history in CSV).
• Withdraw Consent: Opt out of marketing or cookies at any time (no effect on prior processing).
• CCPA-Specific: No data sales occur; non-discrimination for exercising rights; authorized agent form available.

For complaints, contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or California Attorney General. We do not use automated decision-making with legal effects.

5. Cookies and Tracking

We use cookies and similar technologies (e.g., pixels) for essential functions, analytics, and marketing. Our Cookie Policy (linked in the Website footer) provides details and opt-out options. A consent banner is displayed on your first visit, per EU ePrivacy Directive requirements. Disabling cookies via your browser may limit functionality (e.g., wishlist saving).

6. Security and Children's Privacy

We implement encryption and access controls to protect data (GDPR Art. 32). In case of a data breach, affected users will be notified within 72 hours if required (contact support@current.games).

• The Website is not intended for users under 13, and we do not knowingly collect their personal data, per COPPA. If we discover such data, we will delete it promptly.
• Users aged 13–17 require parental consent for purchases, account creation, or wishlists, verified via email confirmation from a guardian or manual ID checks for age-restricted purchases (e.g., PEGI/ESRB 18+).
• No targeted advertising is directed to minors.

7. Future Loyalty Programs

We plan to introduce a loyalty program, which may involve collecting additional data (e.g., points balances, purchase preferences) with your consent. This policy will be updated prior to launch to reflect any new processing activities.

8. Changes to This Policy

We may update this policy, with changes posted on the Website and notified to registered users (e.g., via email). Continued use of the Website constitutes acceptance of updates. Previous versions are available on request.

9. Contact Information

For questions or to exercise your rights, contact:

Current Games B.V.
Stationsplein 10, 9401 LB Assen, The Netherlands
Email: support@current.games (subject: "Privacy Request")