1. PRIVACY NOTICE

1.1. Categories of personal data

We use your personal data only when it is lawful under the applicable privacy law and only to the extent it is necessary to achieve our purposes (please consult Section 1.4). We collect and use the following types of your personal data in connection with your use of the Website and the Services Game.

1.1.1. Customer support data

The customer support data includes data collected and used in connection with customer support provided by us to you. For example, this may include your communication with us as regards your rights as a Consumer, your participation in our surveys or questionnaires or your other requests, questions and queries.

1.1.2. Social media data

The social media data includes data collected and used in connection with your interactions or visits on our social media profiles. For example, this includes your nickname when you reach send us a direct message on Twitter or Telegram and the contents of such message. Please note that social media platforms are independent data controllers. Your use of such platforms is subject to the privacy policies and terms and conditions of such providers of such social media platforms. We encourage you to consult such documents before using such services. We are not responsible for the privacy policies and practices of such social media platforms. For example, you can consult the privacy policy of Twitter  or Telegram.

1.1.3.Tracking data

The tracking data includes data collected and used in connection with use of cookies and similar technologies, such as pixels, beacons, tags, device IDs, Local Shared Objects or tracking pixels. For example, this includes personal data used when we use cookies to remember your settings such as preferred language. Please consult the Cookie Notice to learn more about cookies and similar technologies.

1.1.4. Technical data

The technical data includes data collected and used in connection with the ICT Systems. For example, this includes your IP address, information about your operating system or other software used by your device, hardware details, statistics derived from this data and so on. Generally speaking, most of this information is anonymous data. However, in some cases it may be used to identify you, for example in combination with other data.

1.2. Purposes and legal grounds of processing

We collect and process your personal data in connection with your use of the Website and the Services. As a general rule, we collect your personal data directly from you and from your devices. Generally speaking, we process your personal data to the extent necessary to provide the Services, ensure smooth operation of the Website or for other legitimate purposes. You can find the description of such purposes and legal grounds for processing in greater detail below.

1.2.1. Use of the Website

We process your personal data, such as your IP address or other online identifiers, for the purpose of rendering electronic services within the scope of providing Users with access to the contents collected on the Website. The legal ground for such processing is the necessity of processing for performance of a contract with you (Article 6(1)(b) GDPR).

1.2.2. Security

We process your personal data to ensure the security of the Website and our ICT systems and to manage them. For example, we record some of your personal information in a system logs (special computer program used for storing a chronological record containing information about events and actions related to the ICT Systems used for rendering Services us). The legal ground of the processing is our legitimate interest (Article 6(1)(f) GDPR), which consists of our need to ensure security and safety of our ICT systems used in connection with the Website and the Services.

1.2.3. Social media interaction

We process your personal data for the communication and marketing purposes. For example, to inform you about our activity and promote various events, services and products. We also process your personal data to communicate with you, to promote our brand and for direct marketing purposes, for example to collect your feedback on our products or services. The legal basis of the processing is our legitimate interest (Article 6(1)(f) GDPR), which consists of improving our services, communication with the Users, promotion and marketing. Where required under statutory law, we will be conducting direct marketing activities only with your consent.

1.2.4. Analytics

We process your personal data for analytical and statistical purposes. The legal ground for such processing is our legitimate interest (Article 6(1)(f) GDPR), which consists of conducting analyses of your activity, as well as of your preferences in order to improve functionalities and services provided by us. Where required under statutory law, we will be conducting analytical activities only with your consent.

1.2.5. Compliance

We use your personal data to ensure compliance with the applicable law. For example, this includes processing of your personal data to comply with consumer protection law. We also process your personal data to comply with the GDPR, for example when you submit your request as regards your privacy rights and for accountability purposes. The legal ground for processing is the necessity of processing for compliance with appropriate legal obligation under applicable statutory law to which we are subject (Article6(1)(c) GDPR).

1.2.6. Legal rights

We may process your personal data, if necessary, to establish and assert claims or to defend against claims.  The legal ground for such processing is our legitimate interest (Article 6(1)(f) GDPR), which consist of the protection of our legal rights.

1.2.7. Cookies

We may use your personal data in connection with the use of cookies or similar technologies for purposes described in sections 1.4.1-1.4.6 above. The legal grounds for processing your personal data are (depending on the type of cookies) your consent (Article6(1)(a) GDPR) or necessity of processing for performance of a contract with you (Article 6(1)(b) GDPR). Please consult the Cookie Notice to learn more about cookies and similar technologies.

1.3. Data storage

We store your personal data only as long as necessary for the purposes we collected it. This means that the duration of storage depends on the purpose of processing. For example, we store your personal data for the period of time when we provide you the Services in accordance with the agreement we have entered with you subject to the Terms of Service. We store personal data processed on the basis of legitimate interest(s), our or those of a third party, until you lodge an effective objection to such processing. Similarly, when we process your personal data on the basis of your consent, we store it until you withdraw your consent.

The duration of storage or use of your data may be extended in certain situations. For example, we may store your personal data after you terminate the agreement with us when required by law. We may also continue to store and use the same dataset if we use it for a different purpose and on a different legal basis, if admissible by law. For example, if you terminate the agreement with us, we may continue to use personal data provided by you in connection with your use of the Services when necessary to establish and assert possible claims or to defend against claims (if we have a legitimate interest to do so).

After the end of the period of data storage, we permanently delete or anonymize your personal data.

1.4. Data recipients

As a general rule, we do not share your personal data unless it is necessary. For example, we may share your personal data for example in connection with the provision of the Services under the Terms. We may disclose your personal data to the following categories of recipients:

• external developers or software solution providers,;
• marketing and advertising services providers;
• analytical tools providers;
• data storage providers;
• professional advisors, such as lawyers, accountants and tax advisors.

We require our partners to keep your data secure and confidential under the terms that ensure level of protection essentially equivalent to that described in this Privacy Policy. Please note that some of them and some act as independent controllers of your personal data. If they are controllers of your data, relevant privacy policies and terms and conditions of such controllers may apply. We encourage you to consult such documents before using such services. We are not responsible for the privacy policies and practices of the third parties.

As a general rule, our partners are located in the European Economic Area. However, some of them may be located outside of the EEA, for example in the United States. Please consult Section 1.7 for more details on transfers of your personal data outside of the EEA.

1.5. Data transfers outside the EEA

The level of protection for the Personal Data outside the European Economic Area (EEA) differs from that provided by the EU law. For this reason, we transfer your personal outside the EEA only when necessary and with an adequate level of protection, primarily by cooperating with processors of the personal data in countries for which there has been a relevant European Commission decision finding an adequate level of protection for the Personal Data. Alternatively, we may use the standard contractual clauses issued by the European Commission. If you want to learn more about these safeguards, obtain a copy of them or learn where they have been made available, contact us (please consult Section 1.1 above).

1.6. Requirement to provide personal data

In some cases provision of your personal data is mandatory by law or necessary in order to carry out your request or to perform a contract we have with you. If you fail to provide us with your personal data in such situations, we may not be able to carry out your request, perform a contract with you (or enter into it) or comply with the law. In some cases this may mean that we will terminate the contract or stop our engagement with you. For example, if you do not provide your personal data necessary for the consumer complaint procedure, we may not be able to handle your complaint.

In other cases provision of your personal data is voluntary. If you fail to provide us with your personal data in such situations, we may not be able to carry out your request or achieve our goal. For example, if you do not share your contact details with us, we may not be able to contact you.

1.7. Your rights

To exercise your right(s) contact us (please consult Section 1.1 above).

Depending on where you live, you may have different privacy rights. If the EU law applies to you, you have the following rights under the GDPR:

1.7.1. Right to access information

You can request from us information about the processing of your personal data. You can also request a copy of your personal data that we process from us free of charge. However, under certain conditions set out by privacy law, we may charge a fee for that.

1.7.2. Right to correct your data

You can request that we rectify your personal data that we use, for example, when it is inaccurate. You can also complete your data if it is incomplete.

1.7.3. Right to be forgotten

You can request that we erase your personal data under certain conditions prescribed by law. However, this is not an absolute right and it does not apply in certain conditions, for example, when use of your data is necessary for the establishment, exercise or defence of legal claims by us.

1.7.4. Right to restrict

You can request that we stop processing your personal data, with the exception of storage, under certain conditions prescribed by law. However, this is not an absolute right, and it does not apply in certain conditions, for example when use of your data is necessary for the protection of the rights of another natural or legal person.

1.7.5. Right to data portability

You can request that some of your personal data is provided to you, or to another controller, in a commonly used and machine-readable format. This right applies where we use your data based on your consent or a contract and if the processing of your data is carried out by automated means.

1.7.6. Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal data. You can do this at any time. If you withdraw consent, we will stop using your personal data where the basis for processing is consent. Withdrawal of consent does not affect the lawfulness of processing your data on the basis of consent before withdrawal. The right to withdraw consent applies only to the extent that your personal data is processed on the basis of consent.

1.7.7. Right to object

You have the right to object to the processing of your personal data on the basis of legitimate interest(s), our or those of a third party. You can do this at any time. If you raise an objection, we will stop using your personal data where the basis for processing is our legitimate interest. In exceptional circumstances, we may continue to use your data despite your objection. This exception does not apply when you object to the processing of data for direct marketing purposes, i.e. if you object to it, we will stop processing your personal data on this basis.

1.7.8. Right to lodge a complaint

You can lodge a complaint with the supervisory authority dealing with the protection of personal data. You can lodge such complaint with your local data protection authority or with Maltasian Data Protection Inspectorate, an Maltasian data protection authority based in Valletta, Malta.

2.COOKIE NOTICE

2.1. What are cookies?

Cookies are small text files installed on your device that collect information which, as a general rule, facilitates use of the Website and the Services. For example, cookies may remember your language preferences or other settings of your Internet browser. Generally speaking, in most cases information used in connection with cookies is personal data. In such cases, the Privacy Notice applies to such personal data.

We mainly use our own cookies. We also use Third-Party cookies, i.e. cookies from a domain other than the domain of the visited website, primarily for analytical activities. We may also use other technologies similar to cookies, for example HTML5 local storage, Local Shared Objects or tracking pixels. Where we refer to cookies in this Cookie Notice, we also mean such technologies.

2.2. What cookies are used?

The following types of cookies are used in connection with your use of the Website and the Services.

2.2.1. Necessary cookies

The necessary cookies are the type of cookies that are required by the Website and the Services to function properly. For example, these types of cookies are installed to recall your login sessions and privacy settings. They are set by us. They are mandatory because they are necessary for the provision of the Website and the Services.

2.2.2. Analytical cookies (optional)

The analytical cookies are the type of cookies that enable collecting information such as number of visits and traffic on the Website for statistical purposes. For example, these types of cookies may be installed to analyze how you navigate the Website in order to improve the performance of the Website. They may be set by us or by third-party providers engaged by us. They are optional, so we use them only with your consent.

We use Google Analytics tool provided by Google. Google uses its own Google Analytics cookies to analyze the use of the Website and the Services, and to compile statistics and reports on their operations. We use them to generate such aggregated data. However, because other websites also use Google Analytics, Google may combine cookie data from those sites, which could allow Google to identify you. If you use a Google account, Google may also use such cookie data together with your account. To learn more about Google Analytics and use of your data by Google, please read Google Analytics privacy policy.

2.3. How long are the cookies used?

The duration for which the cookies are used depends on their type and purpose. In general, there are two main types of cookies: session cookies and persistent cookies.

Session cookies expire at the end of a given session. Persistent cookies are stored for a longer period of time on your device. They don’t expire at the end of a given session. The maximum period after which our cookies expire is 12 months.

2.4. Your rights

We use optional cookies only with your consent. You can withdraw the consent at any time. To manage your cookie settings and obtain more information, for example name or duration of specific cookies, you should consult our cookie management platform available here . You can also access the cookie management platform by clicking relevant button on the cookie banner that appears at the bottom of the screen during your first visit to the Website.

You can also manage cookies through your Internet browser, for example by removing all or some cookies from your device or by blocking them. This applies only to cookies used in connection with the Website or the Services which are available online through the Internet browser. Please note that this may cause the Website or the Services to not work properly or at all. To manage cookies through your Internet browser, you should consult instructions provided by the provider of such browser. For example, you can find some of such instructions for relevant Internet browsers on the websites of their developers: Microsoft (Internet Explorer, Edge), Google (Chrome), (Safari), Mozzila(Firefox), Opera(Opera).

Where your personal data is used in connection with cookies, you have the rights described in the Privacy Notice and can exercise them accordingly. Please consult Section 1.9 of the Privacy Notice for more details.