Privacy policy

Last updated: 06.01.2019


This Privacy Policy (hereinafter – the Policy) shall constitute an integral part of the Terms & Conditions (hereinafter – the Terms).

All terms and definitions used in this Policy shall have the same meaning as those in the Terms unless stated otherwise.

You have many rights that you can use to control your privacy. Company respects those rights. We want to help you exercise your rights, so you will find details on how to do so below.

Please take your time to read this policy and contact Company if you have any questions or feedback regarding the Policy.


This Policy contains general and technical information on the measures through which the Company ensures the confidentiality. This Policy shall clarify the policy of the Company, ways of obtaining and using personal data, which the User provides while using the Website or the Services of the Company.

The User shall read carefully this Policy before using the Website or the Services of the Company. By continuing to use the Website or the Services of the Company, the User unconditionally agrees with collection and use of personal information of the User in accordance with this Policy. If after reading this Policy the User has questions and/or doubts regarding this Policy, the User should contact the Company via e-mail info@clubberspot.co.

In the case of disagreement with the Terms and this Policy, the User should not use the Website and the Services of the Company.

The Company recommends to check regularly this Policy since pursuant to Section 8 its terms may be subject to changes.


1. DATA CONTROLLER

Company offices in Kiev, Ukraine are the joint controllers of User’s personal data.

The Company data protection officer can be contacted at e-mail info@clubberspot.co.


2. COLLECTION AND USE OF INFORMATION

The main objective of collection of information about the User is to ensure good quality of and expand the Services, as well as to create conditions whereby the User could easily seek through and use the Website and the Services of the Company. This includes broadcasting of electronic notifications related to the Website and the Services from which the User can unsubscribe at any time by following instructions provided in these notifications.

While using the Website and the Services, the Company can also collect and record information, which the User voluntarily provides to the Company via External Platforms in accordance with terms and policies of such External Platforms.

  • while creating the Account the User shall allow the Company to receive and process the following Account Data:
    • User\`s name, date of birth, place of residence, password, e-mail address, information about his/her page on the External Platform in order to link the Account to the Account page on the External Platform and other information.
  • while using Services, the User shall allow the Company to receive and process the following Tracking Data:
    • information about use by User of the Website or the Services, including inter alia information about time and way of using the Website or the Services, data stream and records of screen elements which the User clicks on while using the Website and the Services (so-called “browsing history”);
    • registration files (logs) and statistic information about activity on the Website.

The User shall not provide any personal data. However, if the User does not indicate part of the requested information, this may result in inability to use the Website or the Services in whole or in part. Provision of the information requested by the Company can be both mandatory and voluntary. If the User does not provide mandatory information, the User will not be able to perform a number of actions, including use of some functions of the Website or the Services.

When using the Website or the Services persons authorized by the Company can collect some technical and routing data about User’s Devices for more convenient use of the Website and related Services. Without a direct notification, the Company shall not establish the link between this information and any other personal data of the User.

Company collects above information by using an automated tool called Google Analytics.

You can learn more about how Google Analytics works and the information it allows the Company to collect and analyse here https://support.google.com/analytics/answer/1012034?hl=lten&ref_topic=6157800

Company uses this data on the basis of its our legitimate interest as a business in improving our understanding of client needs and preferences in order to constantly enhance its Services and improve User access to Website and Services.

You may at any time disable collection of your data by Google Analytics, as described here - https://tools.google.com/dlpage/gaoptout/.

Being aware of the importance of security and confidentiality of such information, the Company shall use services of only well-proven payment services for such transactions. The Company shall not have access and shall not save information about User’s payment cards or bank accounts, except those related to purchase and/or communication with the User on relevant transaction.

Under no circumstances shall the Company request for the information about User’s payment card or bank account, as well as User’s login and password to the Account at the External Platforms or passport data in a manner that is not agreed with the User, including via e-mail or phone.

By contacting Company via e-mail at info@clubberspot.com, User may exercise such rights:

  • to require access to its personal data;
  • to require rectification of its personal data;
  • to require erasure of its personal data;
  • to withdraw consent to processing of personal data, where applicable.

In some cases User may have a right to request a restriction on processing personal data or to object to processing of personal data.

If personal data is erased at User’s request, Company will only retain such copies of the information as are necessary to protect its or third party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement User has entered into with Company.


3. INFORMATION TRANSFER TO THIRD PARTIES

The Company shall not transfer User’s data to third parties, except in cases when the Company must transfer information in accordance with the applicable Legislation, requests of the authorities or law enforcement bodies in order to prevent crimes.

The Company shall have the right to transfer anonymous information (that is information, which does not identify the User directly or indirectly) and the aggregated information (that is information about groups and categories of Users, including statistics and actions, that do not indicate the personality and can not be used to determine the User’s identity) to their advert partners. The Company can also allow its advertisers to collect anonymous information and the aggregated information within the framework of Services provision, use of the Website or the Game; and they can subsequently transfer this information to the Company.

Advertisers of the Company can collect information by means of tracking (for instance, cookie files and web beacons). These technologies allow advertisers to develop and publish targeted advertisements within Services, use of the Website or the Game and on the websites of third parties, as well as to provide the Users with the advertisement of goods and services, which may be interesting for them. Advertisers can also use this information to control, improve or correct their work.


4. COOKIE FILES

Cookie files are used on the Website (cookie files are small files, which are stored on User’s Devices and contain information about the recent activity of the User) to facilitate the authorization procedure, memorize language that the User uses on the Website.

The Company shall have the right to publish on its Website cookie files in order to collect information about visited sections of the Website, about the Services that interested the User and about navigation around the Website. If the User is a registered one, this information is stored in the database of the Company. The Company shall use this information to improve the functioning of the Website, provide the User with additional information and services, as well as for other marketing purposes.

User can control and/or delete cookies - for details, see http://www.youronlinechoices.com/. User can delete all cookies that are already on his/her computer and set most browsers to prevent them from being placed.


5. PERSONAL DATA PROTECTION & ACCESS

The Company aims to protect personal data of the User, while they are under Company’s control. Information about the User’s Account is available only by means of password.

In order to protect personal data confidentiality, the User shall keep the password confidential and shall not disclose it to other persons. The User is responsible for any use of the Website by the third parties, that have the access to the User’s Account. If the User considers that its password or Account were used without authorization – the User shall immediately notify the Company about this.

Statistical data about Users may be accessed by employees in Company’s marketing and IT departments who are responsible for analysing that data and for improving Website.

Partners who provide the Company with Website content management tools or who host the Website may have access to technical log files.

The Google Analytics tool provided by Google Inc. (a US company) has access to statistical data collected by that tool. Google Inc has subscribed to the EU-US Privacy Shield principles EU – US Privacy Shield list, which confirms that what we have provided complies with mandatory EU privacy standards. Contractual obligations to ensure privacy are also applied to this provider, which can be read here: https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20160909.html.

Company uses collected statistical data for analysis for up to 10 years.

Cookies are usually valid for a short term (a day, a week or a month), though in some cases they may remain valid for up to a year.


6. VALIDITY OF THIS POLICY FOR THE RESOURCES OF THIRD PARTIES

This Policy shall apply only to the use of the Website and the process of Service provision. At the same time, the Company expressly warrants that hyperlinks and banners, owned by the third parties are used on the Website, including those leading to the third parties’ websites. Any personal information provided by the User to the relevant third party shall be used in accordance with the privacy policy of the third party.

Websites of third parties and applications shall have their own policy on collection and use of personal information and cookie files.

The Company shall not be liable for the disclosure of confidential information and/or personal data by the User on such websites.


7. USE OF INFORMATION AND DATA RECEIVED FROM MINORS

The Company, acting in a good faith, shall not accept and process intentionally any information and data about persons under the age of 18.

Persons below this age can not use the Website, the Services of the Company, as well as provide personal information and data without prior parental or legal guardians’ consent.

All information, received by the Company about persons under the age of 18, shall be deleted immediately.


8. AMENDMENTS TO THIS POLICY

The Company shall have right to amend this Policy for various reasons, for instance, to reflect changes in Legislation and regulation, industry principles and technical developments.

The current version of the Policy shall be published on the Website. All new versions of this Policy shall enter into force from the moment the amendments are introduced to this Policy and published on the Website. The use of personal data shall be governed by the version of this Policy effective as of the moment of personal data use. By using the Website or the Services of the Company, the User unconditionally accepts amendments of the Policy. In case of disTerms with any amendments to the Policy, the Company recommends the User to delete the Account immediately and stop using the Website and the Services of the Company.