Privacy Policy

This Privacy Policy explains how Individual Entrepreneur (FOP) (hereinafter – the “Rightholder”, “We”) collects, uses and transfers your personal data in connection with the use of the Site and the receipt of the Services. We have made an effort to present the terms as clearly and concisely as possible. If you need additional information or have questions, please contact us using the contact details indicated below. We undertake to treat your personal data with respect and comply with the requirements of the Law of Ukraine “On Personal Data Protection” (hereinafter – the “Law”) and the General Data Protection Regulation (EU) 2016/679 (GDPR). Failure to study or understand the terms set out in this Policy, the User Agreement and the Terms of Use does not release the User from complying with them.

Information we collect

The type of personal information we collect depends on how exactly you interact with the Rightholder and which services you use. We may process the information contained in any request you send to us regarding the Services, including data about your behavior and interaction with the Site.

The data of your request 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 marketing research, checking the effectiveness of advertising and researching similar audiences. The legal basis for such processing is the consent given where the request is made, or your personal consent.

We may process the information contained in any message or related to any message that you send to us, including for hiring purposes. Such correspondence may include your personal data, legal information, projects, etc. The correspondence data may be processed for the purposes of a contract between you and us and/or taking steps, at your request, to enter into such a contract. The 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 Site and business processes, marketing and other communications with Users and clients.

As a rule, we collect the following categories of personal information:

Contact information, such as first name, last name, phone number, social network user ID, email address and similar contact details;
User content, such as the content of messages, suggestions, questions, comments, reviews and other information that you send to us, which 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) addresses and Internet Protocol addresses (IP addresses), device and browser identifiers and information (including device, program or browser type, version, plugin type) and operating system version, 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 publications and similar data (links to the User’s profiles on Facebook, Instagram, Skype, Google, Twitter, 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 for which your prior consent is required, you may withdraw your consent by contacting us at: [email protected]

The Rightholder does not intentionally process biometric personal data (information characterizing the physiological and biological features of a person, on the basis of which their identity can be established) and special categories of personal data (concerning racial or national origin, political views, religious or philosophical beliefs, health status, intimate life).

Our policy is to store and process the personal data necessary to provide you with the best Services. We do not store or process personal data that we do not use. We store personal data for as long as we need it for the purposes set out below: − Personal data is stored in our accounting documents for tax authorities for at least 10 years after you ordered the Service; − Personal data that we process to prevent fraud (users who have committed) we store 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 information

The Rightholder processes personal information about you on one or more of the following grounds:

registration of the User by the Rightholder in the Game and on the Site, providing the User with the opportunity to fully use the services of the Site;
display of the User’s profile on the site, the User’s account;
establishing and maintaining communication between the User and the Rightholder, consulting on issues of fulfilling the terms of the User Agreement, use of the Site;
for the performance of a contract. If the processing is necessary for the performance of a contract;
legitimate interests. If the processing is necessary for the legitimate interests pursued by us or a third party, except where 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 consent to process your personal information for specific purposes;
compliance with the Law. If the processing is necessary to comply with the requirements of legislation.

Dissemination of personal data may be carried out by the Rightholder in the following cases:

when processing personal data for the purpose of displaying the User’s profile to other Users of the Site to support communication, including when providing services remotely;
for the purpose of posting reviews of the services provided by the Rightholder, left by Users, in various sources of information;
for the purpose of posting video materials obtained in the process of providing services in various sources of information;
optimization by the Rightholder of the mailing of informational and advertising messages;
application of organizational and technical measures to ensure the security of personal data during their processing in information systems. Destruction of personal data is carried out by the Rightholder in the following cases: − deletion of personal data by the User in the corresponding section of the User’s Account;
receipt from the User of a withdrawal of consent to the processing of personal data;
receipt from the User of a request for the destruction of personal data;
expiry of the consent;
expiry of the personal data storage period in accordance with the agreements of the Rightholder and the User.

The User’s receipt of Virtual Items may require providing information about your payment methods, in particular credit card data. We do not store or retain this data, and we do not process your payments.

The services provided by Payment Service Providers may be subject to the supervision of financial regulators and are governed by the Payment Service Providers’ agreements applicable to the transaction. The Rightholder takes the necessary and sufficient legal, organizational and technical measures to protect the information provided by Users from unlawful or accidental access, destruction, modification, blocking, copying, dissemination, as well as from other unlawful actions with it.

Location of information

The Rightholder and persons controlled by it are located in Ukraine. While you use our Site and communicate with us, your personal information may be transferred outside the country of your residence and may be stored in and accessible from several countries. Each time we transfer personal information to other jurisdictions, we ensure that the information is transferred in accordance with this Privacy Policy.

Cookies are small data files that are stored on your computer or portable device when you visit certain web pages. They are used as a mechanism for a site to remember actions that the browser performed in the past, for example clicking certain buttons or a previous login. Cookies help us improve interaction with users and allow us to personalize our services, measure which areas and features of our services are popular, and understand how clients use the services.

Necessary cookies (also known as strictly necessary cookies): these are cookies required for the operation of our site. They include, for example, cookies that give you access to secure areas of our Site. Analytical/performance cookies: they 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 improve our Site, for example by ensuring that users can easily find what they are looking for. Functional cookies: they are used to improve the functionality of the Site and make it easier for clients to use the Site. For example, they are used to remember that you previously visited the Site and asked to stay logged in to the Site. Targeting cookies: these cookies record your visit to our site and your browsing habits, for example the pages you have visited and the links you have followed. They are used to show you advertising that is 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 advertising 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 reasons and for personalization. Some of these cookies may be set while a page is loading or when a user performs a certain action on the website. We may use cookies and related technologies described below for various purposes, in particular for site design, Google Tag Manager, advertising, analytics, social networks, etc. On our websites you may see a “cookie banner”. If you consent in this way, we may set advertising cookies on the website. We will periodically show you the banner in case 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 require us to correct any information that you believe is inaccurate. You also have the right to require us to complete information that you believe is incomplete. The right to erasure — you have the right to require the deletion of your personal data under certain conditions. The right to restriction of processing — you have the right to require the restriction of the processing of your personal data under certain conditions. The right to object to processing — you have the right to object to the processing of your personal data under certain conditions. Keep in mind 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 take into account your interests and preferences. You can always withdraw your consent, obtain or require the deletion of all your personal data that we have, or ask a question by sending us an electronic request at [email protected]

The User accepts the terms of the Policy, gives the Rightholder informed and conscious consent to the processing of their personal data on the terms provided for by the Policy and the Law:

upon registration of the User’s Account;
upon entering or changing the personal data of the User’s Account – for personal data that the User provides while editing information on the Site or in the Game;
upon filling in the feedback form;
for personal data that the User provides to the Rightholder when filling in the feedback form on the Internet on the Site and electronic services (Skype, Google, etc.). Upon any use of the Site;
for personal data that is automatically transferred to the Rightholder in the process of using the Site with the help of software installed on the User’s device.

The User is deemed to have given consent to the processing of their personal data at the moment of starting to use the Site. The User’s consent to the processing of their personal data by the Rightholder is valid from the day of giving consent to their processing and for the period necessary to achieve the purposes of processing personal data. If the User has not reached the age of 18, the latter, when providing their personal data, is obliged to send to the Rightholder’s email address the written consent of the User’s legal representative to the processing of such data by the Rightholder. The Rightholder, taking into account the automated system of collecting personal data, does not monitor the provision of such consent by the User. If the incapacity of a User who has provided their personal data without the written permission of their legal representative is revealed, the Rightholder immediately blocks the processing of such personal data until the circumstances are clarified. The Rightholder proceeds from the assumption that the User provides reliable and sufficient personal information on the issues offered in the Site forms and keeps this information up to date. If the User uploads their image through the User’s Account — the User, on a gratuitous basis, gives consent to the use of this image (Article 308 of the Civil Code) for a purpose not related to establishing the User’s identity. The User undertakes not to provide photographs of third parties as the User’s image. The User realizes that the information on the Site posted by the User about themselves may be accessible to other Users of the Site, may be copied and disseminated by such Users in the cases and on the terms specified in cl. of the Policy. The User has familiarized themselves with this Policy and expresses their informed and conscious consent to it.

Limitation of liability. The Rightholder is not liable for possible misuse of personal data and the causing of any harm to the User that occurred as a result of:

technical malfunctions in software and in technical means and networks that are outside the Rightholder’s control;
in connection with intentional or unintentional use of the Site not for its intended purpose by third parties;
failure to ensure the confidentiality of access passwords or intentional transfer of access passwords or other information from the Site by the User themselves, when receiving the Rightholder’s services or using the Site, to other persons who do not have access to this information;
unlawful actions of third parties in accessing the Site’s data, including personal data.

The Rightholder is not liable for the procedure of use of the User’s Personal data by third parties with whom the User interacts within the framework of using the Site. The Rightholder does not verify the existence of a special regime for processing the personal data of Users. If the User is a citizen of the countries of the European Union or a citizen of other states who temporarily or permanently reside in the territory of EU countries and accesses the Site from European countries, the Rightholder takes all reasonable measures to ensure compliance with such requirements of personal data protection legislation. For this, the User is obliged to inform the Rightholder of the existence of a special regime for the protection of personal data by contacting the Rightholder’s email address.

Contact us

The User has the right to send to the Rightholder their requests, including regarding the use of their personal data, as well as the withdrawal of consent to the processing of personal data.

Email: [email protected]