
PRIVACY POLICY
This Privacy Policy explains how Gustilin Hryhorii Oleksandrovych and Grigorenko Alyona Ihorivna (the Copyright Holder) collect, use and transfer your personal data in connection with the use of the Website and the Services. We have done our best to keep the explanations short and easy to understand. But if you need more information or have any questions, please contact us using the contact details below. We are committed to treating your confidential data with respect and comply with the Law of Ukraine “On Personal Data” (the “Law”) and the provisions of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”). Ignorance of the terms and conditions set forth in this Policy, the User Agreement and the Terms of Use shall not be grounds for the User to make any claims against the Copyright Holder.
Information we collect
This Privacy Policy describes the ways in which we collect personal information through this Site and the Game to provide the Services. Your access to the Services and all communications between you and us are governed by this Privacy Policy and applicable law. You can browse this site without disclosing your personal information. However, our Services require you to provide personal information. By submitting personal information, you expressly consent to the collection, use, disclosure and retention of your personal information as described in this Policy, which relates to our processing of your personal information or personal information that may be collected when you are on the Site and use the Site's services.
Тип особистої інформації, яку ми збираємо, залежить від того, як ви конкретно взаємодієте з Правовласником та якими службами ви користуєтеся. Ми можемо обробляти інформацію, що міститься в будь-якому запиті, який ви надсилаєте нам щодо Послуг, включаючи дані про вашу поведінку та взаємодію з Сайтом.
Your request data may be processed for the purpose of responding to your request, providing you with special information about the Services we provide, placing targeted advertising, conducting market research, checking the effectiveness of advertising and researching similar audiences. The legal basis for such processing is the consent provided where the request is made or your personal consent.
We may process information contained in or related to any communication you send us, including for recruitment purposes. Such correspondence may include your personal data, legal information, projects, etc. These correspondences may be processed for the purposes of a contract between you and us and/or taking steps, at your request, to conclude such a contract. Correspondence may also be governed by an NDA (non-disclosure agreement), if applicable. The legal basis for such processing is our legitimate interests: proper administration of our Website and business processes, marketing and other communications with Users and customers.
We generally collect the following categories of personal information:
- − Contact information, such as first name, last name, phone number, social media user ID, email address, and similar contact information;
- - User Content, such as message content, suggestions, questions, comments, feedback, and other information that you send to us, that you provide to us when you contact us and/or receive the Services;
- - Device and browser information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses, device and browser identifiers and information (including device, application or browser type, version, plug-in type) and version, operating system, time zone settings and other technical information, advertising identifiers, cookie identifiers and information and similar data;
- - Demographic information such as country, age and date of birth;
- - Social media and online content, such as information in social media and online profiles, online posts and similar data (links to the User's Facebook, Instagram, Skype, Google, Twitter profiles, etc.);
- - Data on interaction with the Rightholder's advertisements displayed outside the resource, their number, frequency and depth of viewing;
- - Information related to career, education and employment and similar data.
Please note that for any use of your data described above that requires your prior consent, you may withdraw your consent by contacting us at [email protected].
The Copyright Holder does not intentionally process biometric personal data (information characterizing the physiological and biological characteristics of a person, on the basis of which it is possible to establish his or her identity) and special categories of personal data (relating to race, nationality, political views, religious or philosophical beliefs, health, intimate life).
It is our policy to store and process personal data that is necessary to provide you with the best possible Services.We do not store or process personal data that we do not use. We retain personal data for as long as we need it for the purposes set out below: - Personal data is stored in our accounting documents for the tax authorities for at least 10 years after you have ordered the Service;
Personal data that we process for fraud prevention (users who have committed fraud) is stored for at least 5 years after your last login;
- In other cases, your data is stored for no more than 36 months after your last login.
How we use the information
The Copyright Holder processes information about you for one or more of the following reasons:
- − registering the User as the Copyright Holder in the Game and on the Website, providing the User with the opportunity to fully use the Website services;
- - displaying the User's profile on the website, the User's account;
- - establishing and maintaining communication between the User and the Copyright Holder, advising on the fulfillment of the terms of the User Agreement, use of the Website;
- - for the performance of the contract. If the processing is necessary for the performance of the contract;
- - legitimate interests. If the processing is necessary for the legitimate interests pursued by us or a third party, unless such interests are overridden by your interests or fundamental rights and freedoms that require the protection of personal information;
- - your consent. If you have given us your consent to process your personal information for certain purposes;
- - to comply with the law. If processing is necessary to comply with the law.
The Rightholder may disclose personal data in the following cases:
- − when processing personal data in order to display the User's profile for other Users of the Site to maintain communication, including when providing services remotely;
- - for the purpose of posting reviews of the services provided by the Copyright Holder left by the Users in various information sources;
- - for the purpose of placing video materials obtained in the course of providing services in various information sources;
- - optimization by the Right Holder of the distribution of informational and advertising messages;
- - application of organizational and technical measures to ensure the security of personal data during their processing in information systems. The destruction of personal data is carried out by the Copyright Holder in the following cases - deletion of personal data by the User in the relevant section of the User's Account;
- - receipt of the User's withdrawal of consent to the processing of personal data;
- - receiving a request from the User to destroy personal data;
- - expiration of the consent;
- - expiration of the personal data storage period in accordance with the agreements of the Copyright Holder and the User.
In order for you to receive Virtual Items, you may be required to provide information about your payment methods, including credit card information. We do not store or retain this data, nor do we process your payments.
Payments are processed by LiqPay - https://www.liqpay.ua/ and Sense Bank - https://sensebank.ua/ and payment service providers, including acquirers, credit card issuers, your financial institution, etc. The services provided by Payment Service Providers may be subject to supervision by financial regulators and are controlled by the Payment Service Providers' agreements applicable to the transaction. The Copyright Holder shall take necessary and sufficient legal, organizational and technical measures to protect the information provided by the Users from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with it.
Location of information
The copyright holder and its controlled entities are located in Ukraine. During your use of our Site and your communication with us, your personal information may be transferred outside your country of residence and may be stored in and accessed from multiple countries. Whenever we transfer personal information to other jurisdictions, we ensure that the information is transferred in accordance with this Privacy Policy.
Cookie statement
Cookies are small data files that are stored on your computer or handheld device when you visit certain web pages. They are used as a mechanism for a website to remember actions that your browser has taken in the past, such as clicking certain buttons or logging in previously. Cookies help us to improve the user experience and allow us to personalize our services, measure which areas and features of our services are popular, and understand how customers use the services.
Necessary Cookies (also known as strictly necessary cookies): These are cookies that are essential for the operation of our Site. These include, for example, cookies that allow you to access secure areas of our Site. Analytics/Performance Cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our Site while using it. This helps us to improve our Site, for example, by ensuring that users can easily find what they are looking for. Functionality cookies: these are used to improve the functionality of the Site and to make it easier for customers to use the Site. For example, they are used to remember that you have previously visited the Site and asked to remain logged in to the Site. Targeting Cookies: These cookies record your visit to our site and your browsing habits, such as the pages you visited and the links you followed. They are used to show you advertisements that are more relevant to your interests, and they can also be used to limit the number of times you see an advertisement. They may be placed by us or by ad networks with our permission. Please note that these cookies do not contain your personal information. We may also include third-party cookies on our Site, and the collection, use, and choices related to these third-party cookies can be found on such third-party sites. We use cookies for technical and personalization reasons. Some of these cookies may be set when a page is loaded or when a user performs a specific action on a website. We may use cookies and related technologies described below for a variety of purposes, including website design, Google Tag Manager, advertising, analytics, social media, and more. You may see a “cookie banner” on our websites. If you consent in this way, we may set advertising cookies on the website. We will periodically show you the banner if you change your mind.
Your rights
We would like to make sure that you are fully aware of all your data protection rights. Every user has the right to: The right to rectification - you have the right to request that we correct any information that you believe to be inaccurate. You also have the right to request that we complete information that you believe to be incomplete. Right to erasure - you have the right to request that we erase your personal data under certain conditions. The right to restriction of processing - you have the right to request restriction of processing of your personal data under certain conditions. Right to object to processing - you have the right to object to the processing of your personal data under certain conditions. Please note that if you do not allow us to collect your personal information, we may not be able to provide you with certain services, and some of our services may not be tailored to your interests and preferences. You can always withdraw your consent, obtain or request deletion of all your personal data that we hold, or ask questions by sending us an email request to [email protected].
User consent to the processing of personal data
By accepting the terms of the Policy, the User provides the Copyright Holder with an informed and conscious consent to the processing of his/her personal data under the terms and conditions provided for by the Policy and the Law:
- − when registering a User Account;
- - when entering or changing the personal data of the User's Account - for personal data that the User provides when editing information on the Site or in the Game;
- - when filling out the feedback form;
- - for personal data provided by the User to the Copyright Holder when filling out the online feedback form on the Website and electronic services (Skype, Google, etc.). For any use of the Website;
- - for personal data that is automatically transferred to the Copyright Holder in the process of using the Website using the software installed on the User's device.
The User shall be deemed to have given consent to the processing of his/her personal data at the moment of starting to use the Website. The User's consent to the processing of his/her personal data by the Copyright Holder shall be valid from the date of granting consent to their processing and for the period necessary to achieve the purposes of personal data processing. In case the User is under the age of 18, the latter, when providing his/her personal data, shall send to the e-mail address of the Copyright Holder, the written consent of the User's legal representative to the processing of such data by the Copyright Holder. The Copyright Holder, taking into account the automated system of personal data collection, does not monitor the provision of such consent by the User. If the User who provided his/her personal data without the written permission of his/her legal representative is found to be incapacitated, the Copyright Holder shall immediately block the processing of such personal data until the circumstances are clarified. The Rightholder assumes that the User provides accurate and sufficient personal information on the issues proposed in the forms of the Website and keeps this information up to date. If the User uploads his/her image through the User Account, the User agrees to the use of this image free of charge (Article 308 of the Civil Code) for purposes not related to the identification of the User. The User undertakes not to provide photos of third parties as the User's image. The User realizes that the information on the Website posted by the User about himself/herself may be available to other Users of the Website, may be copied and distributed by such Users in the cases and under the conditions specified in clause of the Policy The User is familiarized with this Policy, expresses his/her informed and conscious consent to it.
Limitation of liability The Copyright Holder shall not be liable for any possible misuse of personal data and any damage to the User that may result therefrom:
- − technical malfunctions in the software and in technical means and networks beyond the control of the Right Holder;
- - in connection with the intentional or unintentional use of the Site not for their intended purpose by third parties;
- - failure to ensure the confidentiality of access passwords or intentional transfer of access passwords to other information from the Site by the User when receiving the services of the Copyright holder or using the Site to other persons who do not have access to this information;
- - illegal actions of third parties regarding access to the Website data, including personal data.
The Copyright Holder shall not be responsible for the procedure for the use of the User's Personal Data by third parties with whom the User interacts within the framework of using the Website. The Copyright Holder does not check the existence of a special regime for the processing of Users' personal data. If the User is a citizen of the European Union or a citizen of other states temporarily or permanently residing in the territory of the EU and accesses the Website from European countries, the Copyright Holder shall take all reasonable measures to ensure compliance with such requirements of the personal data protection legislation. To do this, the User is obliged to notify the Copyright Holder of the existence of a special regime for the protection of personal data by contacting the Copyright Holder's e-mail address [email protected] Changes to this Privacy Policy It is expected that this Privacy Policy will change from time to time. The Copyright Holder reserves the right to make changes to the Privacy Policy at any time, for any reason and without notice, except for the publication of the updated Privacy Policy on our Website. We may periodically send email reminders of our notices and terms and conditions, but you should check our Site to review the current Privacy Policy that is in effect and to check for any changes that may have been made to it. Continued use of the Website or its services after the publication of a new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, the User must immediately stop using the Website and its services.
Contact us
The User has the right to send the Copyright Holder his/her requests, including those regarding the use of his/her personal data, as well as withdrawal of consent to the processing of personal data.
Email for communication: [email protected]