Mobile application «HASSLE ONLINE»

This Privacy Policy (hereinafter referred to as the Policy) is an annex to the User Agreement and determines the procedure for processing and protecting personal information about users that HASSLE GAMES LIMITED may receive during their use of the Mobile Application.

Before using the Service, users should read the terms of this Privacy Policy.

«Mobile application» - is software (with all existing additions and enhancements) designed to run on smartphones, tablets, watches and other mobile devices and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application means the HASSLE ONLINE software.

«Controller» - a person who is responsible for the processing and protection of Personal Data of Users located in the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (hereinafter referred to as the "GDRP")

«Personal data» - a set of personal data and / or non-personalized information about the User, provided by him to the Copyright Holder and / or automatically collected by the Copyright Holder and / or third parties.

«User» - a legal or natural person who has downloaded the Mobile Application to a smartphone, tablet or any other mobile device and/or activated such Mobile Application on one of these devices.

«User aggrement» - an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the User's use of the Mobile Application. The user joins such an agreement and does not have the right to make and / or demand any changes or additions to it.

«Copyright Holder» - a person who owns the exclusive rights to own the Mobile Application.

The Copyright Holder of the Mobile Application is:
HASSLE GAMES LIMITED
Registration number: HE 424649
1 Avlonos street, Maria House
Nicosia 1075
Cyprus (Republic of Cyprus)
E-mail: mail@hassle.online

Non-personally identifiable user information

In connection with the use of the Mobile Application, the Copyright Holder may automatically collect and process the following non-personalized information about the User:

• — information about traffic, the possible number of clicks made, logs and other data;
• — information about the device (identification number, mobile operator network) from which you log in, operating system, platform, browser type and other information about the browser, IP address.

User rights for the protection of personal data

In connection with the provision of Personal Data, the User automatically receives the following rights:

• — receive data relating to their processing (grounds and purposes of such processing, methods of processing used, information about persons who have access to them or to whom they can be disclosed on the basis of an agreement or the Law);
• — receive data on the location and identification data of persons performing the processing of Personal Data;
• — receive data on the periods of storage of Personal data;
• — receive data on the performed or proposed cross-border transfer of Personal Data;
• — appeal against the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court;
• — receive compensation for losses and / or compensation for moral damage in a judicial proceeding as a result of violations of the User's rights to the protection and protection of his Personal Data committed by the Copyright Holder and / or third parties;
• — exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy;

Personal data about users

The User provides the Copyright Holder with the following personal data:

• — E-Mail;
• — the most frequently used by the user social networks in which he is registered.

The user is the only person responsible for the completeness of the provided personal (personal) data and is obliged to change them in a timely manner (update, check, correct) on a regular basis.

The Copyright Holder proceeds from the fact that all personal (personal) data provided by the User are reliable, and that the User keeps such information up to date.

Determining the purposes of processing

The collection and processing of Personal Data is carried out for the following purposes:

• — to analyze the User's behavior, as well as to identify the User's preferences for a particular type of content;
• — for the operational and correct operation of the Mobile Application, improving the operation of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application;
• — to identify the User;
• — to provide personalized advertising and marketing materials;
• — to send personalized advertising and marketing materials to the specified email address and / or mobile phone of the User;
• — to comply with the requirements of the Law;
• — to track orders/purchases made by the User through the Mobile Application;
• — to determine the location of the User;
• — for technical support of the Mobile application, identification of problems in its operation and their elimination;
• — to maintain contact with the User (communication);
• — to fulfill other obligations of the Copyright Holder that arose before the User;
• — to conduct statistical research;
• — for any other purposes, subject to obtaining a separate consent from the User;

The processing of Personal Data is carried out on the basis of the following principles:

• — the lawfulness of the purposes and methods of processing;
• — conscientiousness;
• — compliance of the purposes of processing Personal Data with the purposes predetermined and declared when collecting such Personal Data;
• — compliance of the volume and nature of the processed Personal data with the stated purposes of their processing;

Conditions for the processing of personal data

The processing of Personal Data is carried out in the following cases:

• — obtaining consent from the User;
• — achievement by the Copyright Holder of the goals stipulated by an international treaty or the Law;
• — provision by the User of his Personal data to an unlimited circle of persons;
• — fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, the provision of certain content to the User;
• — saving the life or health of the User, when consent to the processing of his Personal Data cannot be obtained in advance;

In case of depersonalization of Personal Data, which does not allow to directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy are no longer applied to them.

The Copyright Holder takes all possible measures to protect the confidentiality of the received Personal Data, except when the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without the use of such automation tools.

Use of remarketing services

The Copyright Holder uses remarketing to advertise the content of the Mobile Application to the User on other sites visited by the User.

Remarketing services are provided to the Copyright Holder through the Google ads platform. Google Ads collects and processes non-personally identifiable data that does not directly allow the User to be identified or identified. The information collected, as a rule, may include the content that the User viewed, the date and time when the User viewed the content, geolocation data. The collection and processing of such non-personalized information allows the User to be provided with more targeted advertising or marketing content.

By installing the Mobile Application, the User agrees to the Privacy Policy for Google Ads and the Terms of Use for Google Ads, as well as the automatic installation of appropriate Cookies on the User's device.

The User has the right to refuse such advertising at any time by changing the appropriate settings of the browser and the device from which the Mobile Application is accessed.

Use of analytical platforms

The Copyright Holder uses the Yandex analytical platform to:

• — tracking the frequency of site visits by Users;
• — tracking the ways in which the User uses the Mobile Application and/or its content;
• — identifying the type and kind of content that is popular among Users;
• — determining the location of the User;

The User also gives his consent to the Copyright Holder to use the information received about the User from Yandex.

For these purposes, the Yandex analytical platform may collect data about the User's IP address, geolocation, behavior, as well as their preferences and interests in relation to certain content.

The Yandex analytical platform gains access to Personal Data in order to provide the Copyright Holder with an understanding of how efficiently its Mobile Application works, what kind of content is popular, how effective it is to place certain advertisements in it, as well as for the purposes of developing and/or improving existing marketing Rightholder's strategies.

By installing the Mobile Application, the User agrees to Yandex's Privacy Policy, as well as to the automatic installation of appropriate Cookies on the User's device.

Disclosure of personal data to third parties

The Copyright Holder has the right to disclose Personal Data:

• — its affiliates, branches and representative offices;
• — to successors of the Copyright Holder who have received exclusive rights to own the Mobile Application;
• — to providers of payment services or banking (financial) institutions, to conduct transactions of the User through the Mobile Application;
• — to third parties solely for the purpose of providing the User with certain content or access to it;
• — to third parties, when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy;

The Copyright Holder discloses Personal Data only if it is sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Copyright Holder takes, and consent to such disclosure was previously expressed by the User and / or is allowed on the basis of the Law.

Mobile Application Advertising

The Copyright Holder, along with the content, places various advertising and marketing materials in the Mobile Application, taking into account the User's identified preferences for this or that content.

The user has the right to refuse such advertising at any time.

Distribution of promotional materials

By installing the Mobile Application on the device, the User automatically agrees with the Copyright Holder's right to send personalized advertising and marketing materials to the provided email address and/or mobile phone.

The User has the right to opt out of receiving such promotional and marketing materials at any time.

Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive any notifications from the Copyright Holder related to the procedure for using the Mobile Application and/or its content.

Request to stop processing personal data

Each User has the right to express his objection to the Copyright Holder against the processing and / or storage of his Personal Data. Such objection may be expressed by sending an appropriate letter to mail@hassle.online.

Change (update, addition, correction) or deletion of personal data

The User has the right to independently change or delete his Personal Data at any time, except in cases where such a change or deletion may lead to a violation of the rules of this Policy, to a violation of the Law. The nature of such Personal Data is evidence in any litigation that has arisen between the Copyright Holder and the User.

The Copyright Holder has the right to delete the User's personal account/profile at any time, as well as all Personal Data about the User, if he has violated the terms of this Policy and/or the User Agreement.

In case of deletion of Personal data about the User, all publications made by such User (comments, ratings, reviews, publication of reports, videos and photos, likes, ratings) and / or any other forms of activity available to the User in Mobile application.

Storage is carried out independently by the Copyright Holder.

Storage is carried out for the following period: 5 years from the date of receipt of such information.

After the expiration of the period of storage of Personal Data, such data is subject to their immediate destruction or depersonalization, unless otherwise prohibited by the Law or the provisions of this Policy.

Protecting the confidentiality of Personal Data is a paramount and important task for the Copyright Holder. The Copyright Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The Copyright Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.

General provisions

The controller in the understanding of this Policy is the Copyright Holder.

The Copyright Holder shall store Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the Member State of the European Union, in whose territory the Mobile Application is available, for storing one or another type of Personal Data. Upon the expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.

Since the Mobile Application is available to users from the European Union, the Copyright Holder undertakes to additionally comply with the provisions of the GDPR.

The Data Controller in relation to the Mobile Application is:

HASSLE GAMES LIMITED
Registration number: HE 424649
1 Avlonos street, Maria House
Nicosia 1075
Cyprus (Republic of Cyprus)
E-mail: mail@hassle.online

For any questions regarding this Policy, our handling of your data, or our compliance with applicable laws, please contact our Data Protection Officer at the above address.

User rights in the field of personal data protection

According to Chapter 3 of the GDPR, Users located in the European Union have the following rights in the field of Personal Data protection:

• — the right to receive information about their Personal Data ("the right to be informed");
• — the right to access your Personal Data ("the right of access");
• — the right to rectification of Personal Data ("the right to rectification");
• — the right to destroy Personal Data ("the right to erasure");
• — the right to restrict the processing of Personal Data ("the right to restrict processing");
• — the right to transfer Personal Data to third parties ("the right to data portability");
• — the right to object ("the right to object");

Availability of Policy text for review

This Policy may be translated into a foreign language for those Users who access the Mobile Application outside the Russian Federation. In the event of a discrepancy between the original text (Russian) and its translation, the original language shall prevail.

This version of the Policy is valid from February 10, 2022.

Changing and addition of the Policy

This Policy may be changed from time to time. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the User.

The user himself undertakes to regularly check the provisions of this Policy for possible changes or additions.

Disclosure risk

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the received personal data, the User is hereby considered to be properly aware that any transfer of Personal data on the Internet cannot be guaranteed secure, and therefore the User carries out such transfer at his own risk.