Freelance Privacy Policy

Freelance Privacy Policy

This document serves to outline and define the Gears for Breakfast ApS Privacy Policy as it relates to our Freelance Agreement (“Agreement”) and applies only to persons that are contracted under said Agreement to perform services for Gears for Breakfast ApS as part of said Agreement.

Date of last Revision: April 30th, 2020


Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual (“Personally Identifying Information”) or that can be connected to you indirectly by linking it to Personally Identifying Information. 

Why We Collect and Process Data

We collect and process Personal Data for the following reasons:

  1. where it is necessary for the performance of our agreement with you;
  2. where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
  3. where it is necessary for the purposes of the legitimate and legal interests of Gears for Breakfast ApS or a third party, except where such interests are overridden by your prevailing legitimate interests and rights; or
  4. where you have given consent to it.

These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you (section 6. below).

What Data We Collect and Process

Basic Data

We will collect your Real Name, Physical Address, Country of Residence, Email Address, Discord User Profile, and other identifying information unique to you that you may provide. This Personal Data allows us to generate appropriate accounts within our systems and services so that you are able to fulfill your obligations under our Agreement. 

Transaction and Payment Data

In order for us to be able to fulfill our obligations under our Agreement we are required to collect and retain your Banking Information and other Personal Data that will allow us to provide payment to you for services rendered under our Agreement. Typical Banking Information may include, but is not limited to, International Bank Account Number (IBAN), Bank SWIFT/BIC Codes, Routing Numbers, and Bank Name and Address information.

Other Data You Explicitly Submit

We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with us or others as related to your fulfilment of our Agreement.

Your Use of the Gears for Breakfast ApS related Websites and Services

We collect a variety of information through your general interaction with the Websites, Content, and Services offered by Gears for Breakfast ApS.

Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions, and application usage data.

Likewise, we may track your process across our websites and applications to verify that you are not a bot and to optimize our services.

Your Use of Games and other Services

In the event that you are to be provided with Games, Content, or other Services as part of our Agreement, we may collect, retain, and use various information about your activity as it relates to the Games, Content, or Services provided. “Content-Related Information” may include (but is not limited to) your Discord ID, Steam ID, Xbox Live ID, and/or PlayStation Network ID , as well as what is usually referred to as “game statistics”. By game statistics we mean information about Game Preferences, progress in the games provided, playtime, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.

How Long We Store Data

We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or — where the applicable law provides for a longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.

In particular:

  • If your Agreement with Gears for Breakfast is terminated, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.
  • Please note that Gears for Breakfast ApS is required to retain certain Personal Data under statutory commercial and tax law for a period of up to ten (10) years.
  • If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

Who Has Access to Data

  • Gears for Breakfast ApS and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in Section 2 above. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.
  • We may also share your Personal Data with our third party providers, affiliates, and partners in connection with Goods, Content, and Services as needed to facilitate the successful fulfillment of our Agreement. Your Personal Data will be used in accordance with this Privacy Policy and only as far as this is necessary.
  • We make certain data related to you available to other members of the Gears for Breakfast Team as is necessary to facilitate reasonable business communications that allow the successful fulfillment of our Agreement.
  • We may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.

Your Rights and Control Mechanisms

The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their Personal Data. While other jurisdictions may provide fewer statutory rights to their citizens, we make the tools designed to exercise such rights available worldwide.

As a resident of the European Economic Area you have the following rights in relation to your Personal Data:

Right of Access

You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access your Personal Data by contacting the designated Data Protection Officer listed at the end of this Policy. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to refuse to act on the request.

Right to Rectification

If we process your Personal Data, we shall endeavor to ensure, by implementing suitable measures, that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you may request it be updated or changed by contacting the designated Data Protection Officer listed at the end of this Policy.

Right to Erasure

You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see Section 2 above) does not exist anymore, or if there is another legal ground for its deletion. For individual items of Personal Data please request an update or change by contacting the designated Data Protection Officer listed at the end of this Policy.

Right to Object

When our processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR / section 2.c) of this Privacy Policy, you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims or for the execution and fulfilment of our Agreement.

You also have the right to lodge a complaint at a supervisory authority.

Right to restriction of processing of your Personal Data

You have the right to obtain restriction of processing of your Personal Data under the conditions set out in article 18 of the GDPR.

Right to Personal Data portability

You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller under the conditions set out in article 20 of the GDPR.

Right to Post-Mortem Control of Your Personal Data

If French data protection legislation is applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of Personal Data after your death in accordance with article 40-1 of the Act No 78-17 of 6 January 1978 on Information, Technology, Data Files and Civil Liberties.

Contact Info

You can contact Gears for Breakfast’s Data Protection Officer using the below information;

Gears for Breakfast ApS
Attn: Data Protection Officer
[email protected]