Privacy Policy
Effective date: April 12, 2022
This Privacy Policy is written in English and may be translated into other languages at the discretion of the Company. The English text is legally binding and shall prevail in the event of any conflict between the Russian text and its translation.
1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US
This Privacy Policy applies to all of our games, websites and related services, collectively referred to as the "Services". Your use of the Services after the effective date is subject to the new Privacy Policy. Your use of our Services and any dispute over privacy matters is governed by this Privacy Policy and our Terms of Service, including any limitations on indemnification and dispute resolution that apply to them. The User Agreement is incorporated into this Privacy Policy by reference.
Please read the following text to learn more about how we use your personal information.
Pursuant to General Data Protection Regulation No. 2016/679 and applicable law (“GDPR”), as well as in accordance with the law on the protection of personal data Federal Law No. 152, Hotger.Games, represented by Sto Startups LLC (referred to as “Hotger.Games" or "we") will be the data controller responsible for all personal data processed by us.
Data Operator: HGPUBLUSHING LIMITED
Email: [email protected]
Address: Pelopos, 5 FIJI SUITES, Flat/Office 101 Potamos Germasogeias, 4040, Limassol, Cyprus
2. WHAT PERSONAL DATA DO WE COLLECT AND WHY?
We may collect, use and process your personal data in a variety of ways.
In all cases, we try to protect your personal data. Each of the sections listed below describes how we receive and process your personal data.
2.1. INDIVIDUAL CLIENTS
We collect personal data from current, prospective and former consumers ("users") of our Services.
A - SOURCES OF PERSONAL DATA
We may receive your personal data from the following sources:
a) directly from you (via the game, website or online forms); and/or
b) from third parties, service providers who assist us in providing you with a particular service (including but not limited to data analytics service providers, operating systems and Internet service providers), or from your social media accounts that you used when registering on our online services (e.g. Facebook*, Google, Game Circle, Weibo).
B - TYPES OF PERSONAL DATA COLLECTED AND PROCESSED
We may collect the following categories of personal data about our users:
a) Contact information (such as the name, nickname or email address you provide when registering for our Services or when logging in via social media);
b) Data about the build version, your account, game progress and in-game events, when you use the Services, we create a Hotger.Games-specific identifier for you, our partners may create their own identifiers;
c) Your IP address and unique mobile device identification numbers (eg, your device ID, advertising ID, MAC address);
d) Data about your device such as manufacturer, operating system, CPU, RAM, browser type, language, current time;
e) Geographic location data (country or city level);
f) Accurate geolocation data (GPS, with your consent);
g) Data we use cookies and other similar technologies to collect Cookie Notice;
h) Data (such as your nickname, email address, avatar) that we receive if you link the Service to a third party service provider's tool (Facebook*, Google, Weibo, etc.);
i) Purchase history, including order details (purchase ID, amount spent, currency, date, time, vouchers and offers used);
j) Data to combat fraud (for example, attempts to abusively claim compensation in games or fraudulent clicks in advertising);
k) Data from the platforms on which the games run (for example, to verify payment);
l) Data for advertising and analytics purposes so that we can offer you better Services;
m) Your email address and messages on the Services and feedback about your experience with us;
n) Other data that you choose to provide to us.
C - REASONS AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
| We may use your personal information to: | Our legal basis for this: |
| We may use your personal information to provide services to you, including providing you with our products and services (for example, playing one of our online games and making purchases online) | Contract |
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
| Establish and manage our relationship (including maintaining or maintaining your account with us, providing support, personalizing your experience with us) | Legitimate interest | - Account Management - Administrative reporting (including at the intra-group level) - Filing or contesting claims |
| To learn about how our products and services are or may be used, or to check, maintain or improve the quality of our products and services (for example, when we ask you to complete a survey about your experience with our services) | - Understanding the market in which we operate - Administrative reporting (including at the intra-group level) | |
| Protect (protect the confidentiality of personal information, prevent unauthorized access to and modification of our systems, and otherwise protect personal data) | - Security control, risk protection, fraud prevention - Administrative reporting (including at the intra-group level) | |
| Provide advertising or marketing services, including informing you about our products, services and events that may be of interest to you, by email or other electronic means | - Promotion of our products and services - Administrative reporting (including at the intra-group level) |
| We may use your personal information to: | Our legal basis for this: |
| Send you marketing emails | Agreement |
D - PERIOD OF RETENTION OF PERSONAL DATA
We will only process your personal data for as long as is necessary for the purposes for which it was collected in connection with the provision of services to you, unless we have a legal right or obligation to retain the data for a longer period, or when these data are necessary to substantiate, bring or challenge legal claims.
2.2. REPRESENTATIVES OF OUR CURRENT OR PROSPECTIVE CORPORATE CUSTOMERS, BUSINESS PARTNERS AND SUPPLIERS
We may collect personal information about employees, officers, designees and others associated with current and prospective corporate clients, business partners and suppliers of Hotger.Games.
A - DATA SOURCES
We may receive your personal data from the following sources:
a) directly from you;
b) from your employer if you are an employee of our current or prospective client, business partner or supplier;
c) in the course of networking events in which we host, sponsor or participate, including on behalf of networking event hosts; and/or
d) from publicly available sources (for example, your company website or social networks such as LinkedIn).
B - TYPES OF PERSONAL DATA COLLECTED AND PROCESSED
We may collect the following categories of personal information about employees, officers, designees and others of our current and prospective customers, business partners and suppliers:
a) name;
b) the address of the place of work;
c) business email address;
d) business phone number; and/or
e) position.
C - REASONS AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
| Provide you with our products and services or receive products and services from you | Legitimate interest | - Efficient execution of our contractual and legal obligations - Administrative reporting (including at the intra-group level) |
| Establish and manage our relationships | - Efficient execution of our contractual and legal obligations - Account management - Understanding the market in which we operate - Administrative reporting (including at the intra-group level) - Filing or contesting claims | |
| Learn about how our products and services are used or can be used | - Understanding the market in which we operate - Administrative reporting (including at the intra-group level) | |
| Provide safety | - Security control, risk protection, fraud prevention - Administrative reporting (including at the intra-group level) | |
| Communicate to you about our products, services and events that may be of interest to you by email or other electronic means | - Promotion of our products and services - Administrative reporting (including at the intra-group level) |
If you object to our use of your personal information for the above purposes, including direct marketing, please email us at the address set out in Section 1.
Where we use cookies and similar technologies, we will ask for your prior consent where required by law.When we use your email address to send you marketing information, we will ask for your prior consent if required by law.
D - PERIOD OF RETENTION OF PERSONAL DATA
We will only process your personal data for as long as is necessary for the purposes for which it was collected in connection with your business relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or when this data is necessary for the establishment, assertion or defense of legal claims.
2.3. SITE VISITORS
We may receive your personal data from the following sources:
a) directly from you (for example, when subscribing to services offered on our site, including, but not limited to, email newsletters, interactive services, hosted materials); and/or
b) from your device or browser through internet service providers, operating systems and platforms, and data analytics service providers. If you contact us, we may keep a record of your contact.
A - TYPES OF PERSONAL DATA COLLECTED AND PROCESSED
a) browser type;
b) information about the use of our site (eg pages visited, geographic location, time spent on the site, online activities);
c) cookie data (see our Cookie Notice for details);
d) online marketing preferences; and/or
e) IP address.
B - REASONS AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
| To provide you with the services of our website | Legitimate interest | - Site management - Promotion of our products and services - Account Management |
| Establish and manage our relationships | - Understanding the market in which we operate - Administrative reporting (including at the intra-group level) - Account Management | |
| Learn about visitor behavior on our site(s) and the performance of the site(s), incl. to check or maintain and improve the quality of our site, products and services | Site management | |
| Maintain security (including protecting the confidentiality of personal information, preventing unauthorized access to and modification of our systems, and otherwise protecting personal information) | - Security control, risk protection, crime prevention - Administrative reporting (including at the intra-group level) | |
| Provide advertising or marketing services, including communication, including informing you about our products, services and events that may be of interest to you, by email or other electronic means | - Promotion of our products and services - Administrative reporting (including at the intra-group level) | |
| Learn about how our products or services may be used, incl. to test, maintain or improve the quality of our products and services | - Understanding the market in which we operate - Administrative reporting (including at the intra-group level) |
If you object to our use of your personal information for the above purposes, including direct marketing, please email us at the address set out in Section 1.
Where we use cookies and similar technologies, we will ask for your prior consent where required by law.
When we use your email address to send you marketing information, we will ask for your prior consent if required by law.
C - PERIOD OF RETENTION OF PERSONAL DATA
We will only keep your personal data for as long as necessary for the purposes for which it was collected in connection with your inquiries through our site or your use of our site.
2.4. VISITORS TO OUR OFFICES
A - SOURCES OF PERSONAL DATA
We may receive your personal data directly from you or from our records on our operating systems or on our platforms.
B - TYPES OF PERSONAL DATA COLLECTED AND PROCESSED
a) name;
b) official contact details;
c) organization;
d) role;
e) the time and date of your visit; and/or
f) image (for example, from CCTV cameras in our offices).
C - REASONS AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
| Provide safety | Legitimate interest | Security control, risk protection, crime prevention |
| Keep a record of visitors to our offices | Legitimate interest | Administrative reporting |
If you object to our use of your personal data for the above purposes, please let us know by e-mail at the address set out in section 1.
D - PERIOD OF RETENTION OF PERSONAL DATA
We retain your personal data for as long as necessary to ensure the safety of visitors to our offices, and when it is no longer necessary (usually after 90 days), we delete it.
3. TO WHOM WE SHARE YOUR PERSONAL DATA
Our partners and service providers
We may disclose information about you to organizations that provide services to us, while obliging them by contract to keep your personal data confidential and comply with the GDPR, as well as 152 FZ and other data protection laws.
We may share your information with the following types of service providers:
a) technical support providers who maintain our website and IT infrastructure;
b) software providers, incl. software-as-a-service solution providers, where the provider stores relevant personal data on our behalf;
c) professional advisors such as lawyers, accountants, tax advisors, auditors, insurance brokers;
d) providers who help us compile reviews of our products and services;
e) our advertising and marketing agencies and consultants, and organizations and online platforms that we have selected to conduct marketing campaigns on our behalf and to advertise their own products and services that may be of interest to you.
f) service providers who help us provide our services.
Law enforcement and government departments
We may disclose your personal information as permitted by law to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our intellectual property rights, situations that pose a potential threat to the physical safety of any person, violations of our Terms and other agreements, or the requirement of the law.
4. TRANSFER OF PERSONAL DATA OUTSIDE THE EU/EUROPEAN ECONOMIC AREA
We share your personal data with our affiliates and partners in the EU/EEA and outside the EU/EEA. In cases where the transfer of data outside the EU/EEA is not subject to a decision on the adequacy of the measures of the EU Commission, we are guided by the security measures described in Art. 46 and subsequent articles of the GDPR, as well as 152 FZ in the territory of the Russian Federation. First of all, they include approved by the EU Commission
Standard Contractual Clauses, which we have reinforced with additional safeguards such as supporting individual risk assessments, additional contractual and technical security measures, including additional encryption or pseudonymization, to enable data transfer to Hotger.Games affiliates and partners outside the EU/EEA. The full text of the Standard Contractual Clauses approved by the EU Commission can be found here.
For more information about data transfers to third countries, as well as our security measures and additional protections, please email us at [email protected].
We share your personal data with external vendors or service providers that we engage to perform services or functions on our behalf and in accordance with our instructions. Where such suppliers are located in the EU, we ensure that they are contractually bound to comply with EU data protection regulations. In our contracts with these organizations, we also direct them to process personal data only in accordance with our instructions and only in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers and consultants, law enforcement and other government departments (including tax and social security authorities), police, prosecutors, courts and judicial divisions. All such recipients are solely responsible for complying with EU data protection regulations.
Some of the suppliers we engage are located outside the European Economic Area. In cases where the EU Commission has not recognized these areas as providing adequate protection for personal data, we rely on the security measures described above.
You can request a copy of these agreements by sending an email to the address provided above in the section "Who is responsible for processing your data and how to contact us".
5. YOUR RIGHTS UNDER GDPR
You have the right to receive information from us about how we handle your personal data, to see copies of all personal data we hold, and to request that we change, correct or delete your personal data from our systems. You can also impose restrictions and prohibitions or object to the processing of your data.
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