PRIVACY POLICY

 

Last Updated: 24/05/2023

(We are entitled from time to time to make changes to this Privacy Policy).

 

This Privacy Policy (hereinafter referred to as "Policy") was prepared by Gameback LTD, UK incorporated company, with company number 14598782 , registered office at Suite 17027 43 Bedford Street, London, United Kingdom, WC2E 9HA (hereinafter referred to as "Company") in accordance with the provisions and requirements of applicable law, and aims to regulate and determine the conditions of any information, including information about personal user data that the Company may receive about the User when the latter uses the Company-owned sites, programs, applications, services (hereinafter referred to as "Company Products"), as well as in the course of the Company’s obligations to users.

 

1. GENERAL PROVISIONS

 

1.1 This Policy is a legally binding document for all Users who use the Company’s Products and enter into a relationship with the Company.

1.2 Each User undertakes to read this Policy. Acceptance of this Policy is a prerequisite for the use of the Company’s Products and for entering into a relationship with the Company.

1.3 The Company shall process personal data in full compliance with the rules and regulations of international law and legislation of the European Union, United Kingdom and Ukraine, namely, but not limited to, those specified in accordance with the following regulations:

 

• EU law 2016/679 (GDPR).

• The UK Data Protection Act 2018.

• The Law of Ukraine on the Protection of Personal Data

 

2. PURPOSE OF THE POLICY AND PERSONAL DATA

 

2.1 The purpose of this Policy is to ensure that information about Users, including their personal data, is protected from unauthorised access by third parties and to define the procedure for obtaining, sharing and using information about Users.

2.2 The Company takes all possible measures and conducts as much as possible to protect and safeguard the personal data of Users.

2.3 The Company shall in particular, but not limited to, obtain and process the following personal data and information about you:

 

• Registration information.

 

Includes the information received from the User when filling in the registration and feedback forms on the Products of the Company, in particular the name, surname, other personal data of the identification document (if necessary), pseudonym, e-mail address, IP address, cookies, other data specified by the User.

 

• Technical information.

Includes information from software, technical and hardware services (software, etc.) applied by the User when using the Company’s Products, information obtained using Google Analytics web analytics tools, including, but not limited to, the following information:

- information about the devices Users use when using the Company’s Products, including operating system model and version, unique device identifiers, as well as information about the mobile network and phone number from which the User uses the Company’s Product;

- information recorded in server logs, in particular information about User search queries, cookies, IP address, system failures, data about User browsing on certain pages of the Company’s Products;

- information on the territorial location of the User provided via the Internet, etc;

- information about the domain (subdomain) of the User’s provider, country of residence, etc.

 

• Trade information.

 

Includes information provided by the User to the Company or other Users as part of the ordering process, correspondence, discussion of payment details as well as other information related to the receipt and execution of Company services, including but not limited to: account details, login details, password and other attributes necessary to access the account, e-mail address.

 

• Payment information.

 

Includes information on the details of the means of payment used by the User to pay for Company services, in particular, but not limited to, bank account number, e-wallet number, etc.

 

• Activity information.

 

Includes information on purchases and orders made on Company Products, interactions with other Users, feedback on third-party services, and comments on the quality of Company Products.

 

• Third-party information.

 

Includes information that the Company may receive from its counterparties: from other services, programmes, websites (e.g. the Company’s advertisers). In such cases, the processing of personal data of Users is possible under the conditions established by applicable law and is carried out on the basis of special agreements of the Company with the counterparties.

 

• Personal information.

 

We do not knowingly collect personal data such as racial origin, political opinions, health information or biometric data, except as required by applicable law.

 

• Cookies.

 

Cookies are used by the Company to analyse the actions of Users and to display the Company’s Products in a format that is convenient for you (for example, browsing in the language you have previously chosen). The Company uses session cookies in order to make the use of the Company’s Products more convenient (for example, your choice during authorisation or when taking a test). Session cookies expire at the end of your session, when you close the Company Product page or browser window you are using.

 

3. PURPOSE OF PERSONAL DATA PROCESSING

 

2.1 The Company processes information, including the User’s personal data, in order to fulfil its contractual obligations to the Users, improve the quality of the Company’s services and improve the Company’s Products. This includes using it for purposes such as:

• Creating, verifying, and managing user accounts and functions;

• Providing, supporting and assisting with communication of the Company Services, including responding to inquiries, processing transactions or requests, and communicating with users (e.g., sending messages and updates related to services and accounts);

• Developing, delivering and improving the Company's Services and other offerings, some of which may be offered in partnership with other parties;

• Personalizing your experience, including by providing content or features better tailored to you or your interests, or our findings about your interests (e.g., if you play a certain genre of games frequently, we may infer that you are interested in that genre and offer you similar games)

• Promoting the Company's Services, including managing, customizing and measuring the effectiveness of our advertising, promotional offers, surveys and events;

• Conducting data analytics (e.g., analyzing how Company Services are used so that we can better understand, improve and personalize them);

• Complying with our contractual obligations and enforcing our terms;

• Ensuring the security of the Company's Services, such as detecting fraud and otherwise protecting the Company and other users from illegal or harmful activities.

3.2 The Company will also process the User’s personal data where this is required by applicable law or to protect the interests of the Company, unless it is detrimental or prejudicial to the rights and interests of Users.

3.3 Processing of personal data is subject to access to your account, including account settings and other Company Product tools

 

4. NOTICES AND ASSURANCES

 

4.1 The User hereby acknowledges and agrees that the transfer of information and personal data about him/herself to the Company is voluntary and at the sole discretion of the User. By posting personal data on the Company’s Products, the User acknowledges that they do so voluntarily, and that they voluntarily provide it to the Company for processing.

4.2 The User hereby confirms that by using the services of the Company’s Products, they consent to the processing of their personal data in accordance with the provisions of applicable law. The Company has the right to use the User’s personal data for the purposes set out in this Policy.

4.3 The User hereby consents to receive various sms, emails and other forms of sending/receiving information, including advertising content, from the Company.

4.4 The Company does not verify the accuracy of the information provided by or received from Users, nor does it monitor their legal capacity. It is presumed and the Company assumes that in all cases, without exception, the User provides complete and accurate information about themselves and keeps this information up to date.

4.5 When processing Users’ personal data, the Company undertakes to take all organisational and technical measures to protect it from unauthorised access in a manner not permitted by the Company’s Products. However, it is possible that as a result of a failure in the operation of the Company’s Products, a virus or hacker attack, technical failures or other circumstances, the Users’ personal data may become available to other parties. The Company shall not be liable for possible misuse of User’s information that occurs without notifying the Company, with or without a breach of information security of the Company’s Products.

 

5. USER RIGHTS

 

5.1 The Company warrants to each User (to the extent not contrary to applicable law):

• The right to access and read the information the Company processes about the User in accordance with this Policy;

• The right to supplement, amend, modify and delete information about the User, in whole or in part, in particular by withdrawing its consent to the processing of personal data provided under this Policy;

• The right to restrict the processing of information about the User;

• The right to receive copies of documents related to the storage and transmission of User information.

 

6. TRANSFER OF USER INFORMATION

 

6.1 The transfer of information about the User is made by the Company subject only to compliance with all terms and conditions set out in the applicable law.

6.2 Subject to the above and where permitted under applicable law, information about the User may be passed on by the Company:

6.2.1 to its employees, affiliates and third parties involved in the provision of the Services by the Company, to provide the use of the Company’s Products to Users performing analytics of the Company (in particular to Google Analytics, other similar services);

6.2.2. to state authorities, including law enforcement bodies, bodies of enquiry and investigation, courts, local authorities upon their motivated request;

6.2.3 on the basis of a court order to third parties other than the third parties referred to in clause 6.2.1 of the Policy;

6.2.4 in other cases provided for by applicable law.

6.3 The level of protection of personal data in some countries may not be the same as that of your jurisdiction. By using the Company’s Products, the User agrees and accepts the condition referred to in this clause.

 

7. INFORMATION STORAGE

 

7.1 The recording, systematization, accumulation, storage, clarification (modification) and retrieval of information about Users shall be carried out using databases within the EEA.

7.2 The retention period for User information is for as long as is necessary to achieve the purpose for which they were collected or to comply with applicable law, but no more than 5 years.

7.3 At the end of the retention period, information about the User shall be deleted or made anonymous.

7.4 The user has the right to delete personal information as well as any other information posted by him on the services of the Company’s Products. To do so, the User shall contact the Company by email: [email protected] with a request to delete or change the User’s personal data.

 

8. DISPUTE RESOLUTION PROCEDURE

 

8.1 The Website Administration and the User hereby established a pre-trial complaint procedure for settling disagreements and disputes arising from the application of this Policy. The deadline for responding to the submitted complaint shall be 10 (ten) working days from the date of its receipt.

8.2 If no agreement is reached on a dispute arising from this Policy, the dispute shall be subject to judicial review in accordance with applicable law at the location of the Site Administration.

 

9. CONCLUDING PROVISIONS

 

9.1 This Policy shall take effect as soon as it is posted on the Internet at https://gamingspay.com. An up-to-date version of the Policy shall be posted on the said page.

9.2 This Policy shall be in force indefinitely and shall lapse on revocation by the Company.

9.3 The use of any Company Product may be subject to additional terms or a separate agreement in relation to the processing of Users’ personal data, which may amend this Policy and/or have special conditions governing the relationship arising between the Company and the Users of the relevant Company Products. The said additional terms or Agreements shall be placed in specific sections of such Company’s Products.

9.4 In case of amendments to the Policy, such amendments shall become effective on the date of publication of the new version of the Policy at: https://gamingspay.com, unless a different effective date is additionally determined when publishing it. The Company shall be entitled to unilaterally amend the text of the Policy.

9.5 The User undertakes to independently monitor changes in the provisions of this Policy. In the event of material changes in the provisions of this Policy, the Company shall inform Users thereof by any available means, including by publishing the relevant message (notice) on the pages of the Company’s Products and/or sending a message (notice) to Users’ emails or personal accounts (accounts).

9.6 If the User does not agree with the relevant changes, the User must stop using the Company’s Products and abandon any relationship with the Company. Otherwise, the User’s continued use of the Company’s Products shall mean that the User agrees to the terms of the revised Policy.

9.7 Questions, suggestions and complaints relating to the processing of personal data of Users may be directed by the latter via the following communication channels:

• Feedback form <a href="mailto:[email protected]">[email protected]</a>:

• Email address <a href="mailto:[email protected]">[email protected]</a>.

9.8 This Policy has been written in English. In the event of any inconsistency between the English language version of the Policy and the version of the Policy translated into another language, the English language version shall take precedence and apply directly.