Privacy Policy for the PacMap Japan Application
Version: 1.0
Effective date: September 1, 2026
Applies to: PacMap Japan application, version 1.1.0-Japan
1. Scope of this Policy
This Privacy Policy describes the processing of personal data in the PacMap Japan desktop application when EnviroSolutions Sp. z o.o. is the data controller and the organizer of the game or event.
The application operates locally on the device. It does not require user accounts, an internet backend, telemetry, advertising, or automatic synchronization of rankings with a server.
If the application is used by another organizer who independently determines the purposes and means of processing participants’ data, that organizer is a separate data controller. Before collecting any data, such organizer should provide participants with its own information regarding the identity of the controller, the purposes and legal basis of processing, the retention period, and the manner in which data subjects may exercise their rights.
2. Data Controller and Contact Information
The data controller is:
EnviroSolutions Sp. z o.o.
ul. Górczewska 222/148
01-460 Warsaw, Poland
Tax Identification Number (NIP): 123-128-84-96
National Court Register (KRS): 0000518057
For privacy-related matters and exercising data protection rights, please contact:
E-mail: office@envirosolutions.pl
Telephone: +48 505 944 460
By post: at the address indicated above.
If the Data Controller appoints a Data Protection Officer, the officer’s current contact details will be made available together with this Privacy Policy.
3. What Data the Application Processes
Ranking Data
When starting a game, the standard form requires the following information:
player’s name or nickname,
telephone number.
The following information is added to the ranking entry:
score,
level achieved,
date and time when the entry was created,
technical identifier of the entry.
The application compares the normalized player name and telephone number with existing ranking entries in order to reduce the creation of duplicate entries for the same combination of data.
Local Preferences
The application may store the following information locally on the device:
selected language,
sound settings,
board and intro scaling,
path to the selected ranking export file.
This information is used solely to restore and maintain the application’s settings. The application does not create a user profile based on this information.
4. Purposes and Legal Bases for Processing
The Data Controller processes ranking data for the following purposes:
maintaining a local ranking of participants,
attributing a score to a participant,
preventing duplicate submissions,
operating and securing the game or event.
The legal basis for processing is the legitimate interest of the Data Controller in organizing the game, maintaining a reliable ranking, and preventing abuse, pursuant to Article 6(1)(f) of the GDPR.
A participant has the right to object to such processing.
If a particular game or event is conducted on the basis of competition rules, a contract, or consent, the organizer should inform the participant of the applicable additional legal basis before collecting the data.
The telephone number is not used by the application itself for marketing purposes. Marketing communications require a separate legal basis and are not covered by this Privacy Policy.
Local preferences are stored in order to ensure the proper operation of the application and provide a convenient user experience.
5. Is Providing Data Mandatory?
Providing the player’s name and telephone number is voluntary, but these details are required by the standard form used to start the game and create a ranking entry. Failure to provide this information prevents the participant from completing that form.
The application does not make decisions that produce legal effects or similarly significantly affect a participant. The ranking is automatically ordered according to the score and, in the event of a tie, according to the time at which the entry was created.
6. Where and How Data Is Stored
Ranking data is stored locally in the application’s memory on the device, using the renderer’s localStorage mechanism in Electron. The application does not automatically transmit this data to EnviroSolutions, Microsoft, or any other entity.
An authorized device operator may optionally select a text file and export the complete ranking to that file. The exported file contains the data in readable, unencrypted form. It is stored in a location selected by the operator and remains outside the application’s control.
The application does not apply additional encryption to data stored in localStorage or to the exported file. Data protection therefore depends on the security of the operating system account, the device, backups, and permissions applicable to the selected file. A device used during an event should be protected against access by unauthorized persons.
7. Retention Period and Deletion
The application does not automatically delete ranking entries. The Data Controller retains the data for as long as necessary to fulfill the purpose of the relevant game or event and to handle any related claims, and subsequently deletes the data without undue delay, unless further retention is required by law.
An operator may delete the ranking through the application’s protected settings. Deleting the application data or uninstalling the application may remove the local database, depending on the operation of the operating system.
Exported files and their backups must be deleted separately from the locations in which they have been stored.
Before using the application during an event, the Data Controller should establish and enforce a specific data deletion schedule appropriate to the purpose of the event.
8. Recipients of Data
Data may be accessed only by:
persons authorized by the Data Controller to operate the device, event, or ranking;
technical support providers acting on documented instructions from the Data Controller, where access is necessary;
public authorities, where disclosure is required by law.
The application does not disclose data to advertisers, analytics networks, or data brokers. It does not perform automatic transfers of data outside the European Economic Area.
Microsoft may independently process data associated with a Microsoft Store account, download, installation, or operation of the platform. Such processing is not performed by PacMap Japan and is subject to Microsoft’s Privacy Policy.
9. Rights of Data Subjects
Under the conditions set out in the GDPR, a participant may request:
access to their personal data and a copy of such data;
rectification of inaccurate or incomplete data;
erasure of personal data;
restriction of processing;
data portability, where applicable;
objection to processing based on the legitimate interests of the Data Controller.
Requests may be submitted to office@envirosolutions.pl.
It is advisable to provide the name of the event, the approximate date of participation, and information that may help identify the relevant ranking entry. Before fulfilling a request, the Data Controller may request information necessary to verify the identity of the requester.
Because the application does not transmit data to a server, EnviroSolutions may not have access to data stored exclusively on a device operated by another organizer or user. In such cases, the request should be directed to the entity controlling the relevant device or exported file.
A participant also has the right to lodge a complaint with the President of the Personal Data Protection Office (UODO). Current information about the authority is available at uodo.gov.pl.
10. Children’s Data
The application does not verify the user’s age. The event organizer should establish rules governing the participation of minors and provide appropriate information and involve a parent or legal guardian where required by applicable law or the nature of the event.
11. Changes to the Purpose or Functionality of the Application
This Privacy Policy does not cover future features such as online rankings, user accounts, analytics, advertising, cloud services, transmission of data to partners, or marketing communications.
Before introducing any such feature, the Data Controller will update this Privacy Policy and, where required, obtain appropriate consent or identify another applicable legal basis for processing.
12. Changes to this Privacy Policy
This Privacy Policy will be updated whenever the operation of the application, the scope of data collected, the purposes of processing, or applicable legal requirements change.
The current version should be made available within the application or at the address specified in its Microsoft Store listing. The effective date is stated at the beginning of this document.