Privacy policy

February 28, 2018

by andrei4digital

PERSONAL DATA PROCESSING POLICY

or

PRIVACY POLICY

This privacy statement explains all aspects of the processing of personal data and ensures compliance with all the processing principles established by the legislation in force and by Regulation (EU) 679/2016 (GDPR) by Crowngem Limited (hereinafter referred to as the “Company” or “the Controller”).

The company operates the online websites game.footballcoin.io and footballcoin.io

Any processing carried out wholly or partly by automated means and the processing by non-automated means of personal data which are part of a data recording system or which are intended to be part of a data recording system, we will ensure that your data is:

  • processed legally, fairly and transparently;
  • collected for determined, explicit and legitimate purposes and not subsequently processed in a way incompatible with these purposes; further processing for purposes of archiving in the public interest, for scientific or historical research purposes or for statistical purposes is not considered incompatible with the original purposes;
  • relevant and limited to what is required in relation to the purposes for which they are processed.
  • accurate and, if necessary, up-to-date, we will take all necessary measures to ensure that personal data which are inaccurate, in view of the purposes for which they are processed, are erased or rectified without delay;
  • kept in a form that allows to identify yourself for a period that does not exceed the time required to meet the purposes for which data is processed; personal data will be stored for longer periods as long as they are processed solely for purposes of archiving in the public interest for scientific or historical research purposes or for statistical purposes;
  • processed in a way that ensures adequate security, including protection against unauthorized or unlawful processing and against loss, destruction or accidental damage, by taking appropriate technical or organizational measures.

Our services are dynamic and we frequently introduce new functionalities, which may require the collection of new information. If we collect personal data with material differences or make material changes to the way we use the data, we will notify you and we may also change this privacy policy.

1. WHAT ARE THE PURPOSES FOR PROCESSING YOUR PERSONAL DATA?

The primary purpose for which we process your personal data is to ensure that the contractual arrangements between us can be properly implemented so that the relationship can work smoothly and comply with legal requirements.

The company will process the data for the following purposes:

  • Providing access to the Football Coin platform;
  • Creation of the account on our platform;
  • Marketing and advertising.

If we intend to further process your personal data for a purpose other than the one for which it was collected, we will provide you, before this further processing, with information on the purpose of the processing and any additional relevant information requested by you that include:

the period for which personal data will be stored and the criteria used to determine this period;

  • the existence of the right to request, access, rectification or erasure of your personal data, or restrict the processing or the right to oppose your processing, as well as the right to data portability;
  • when the processing is based on your consent to the processing of personal data for one or more specific purposes, the existence of the right to withdraw your consent at any time without affecting the lawfulness of the processing under consent prior to its withdrawal;
  • the right to lodge a complaint with a supervisory authority;
  • whether the processing of personal data is a legal or contractual obligation or obligation required to conclude a contract and whether you are required to provide such personal data and what are the possible consequences of non-compliance with that obligation;
  • the existence of an automated decision-making process including the creation of profiles, as well as, at least in those cases, relevant information on the logic used and the expected importance and consequences of such processing for your individual

2. WHAT IS THE LEGAL BASE USING FOR THE PROCESSING OF YOUR PERSONAL DATA?

Your personal data is used to:

  • The purpose of providing access to our products / services – these being necessary for the execution of a contract to which the data subject represents the legal representative of the company is a party or to take steps at the request of the data subject prior to the conclusion of a contract (Article 6 (1) b) of GDPR);
  • The purpose of marketing and advertising – these being used by us in a legitimate interest (Article 6 (1) f) of GDPR);

3. WHAT TYPE DATA WE COLLECT?

We collect data to work efficiently and provide you with the best experiences with our products. You can opt for the data we collect. When asked to provide personal data, you can refuse. If you choose not to provide data that is required to provide a product, you may not be able to use the product.

For each purpose of the processing, we need some personal data from you as follows:

  • The purpose of providing access to our services / products – [username, email address, telephone number, age, IP, transaction history, stats and leaderboards]; Failure to transmit this information will make it impossible to provide you our services;
  • The purpose of marketing and advertising – [email address, phone number, data collected from cookies]; Failure to transmit this information will make it impossible for us to offer personalized marketing campaigns to you;
  • We can combine personal information with information about your online transactions and other interactions with us. We can also combine personal information with information we receive from other sources, such as marketing partners, public databases, publicly accessible pages on social platforms, and other third parties.

4. HOW DO WE USE THE PERSONAL DATA?

We will only use personal data for the purpose for which it was collected and will only store the data for as long as necessary for that purpose. We will keep your information for as long as your account is active to provide you with services in order to comply with our legal obligations or for any of the above purposes. Access to personal data is strictly limited to our staff, according to data protection work procedures.

We will mainly use your information to perform the following tasks:

  • To communicate with you and to send you information by email, mail, phone, text message or other means about our products, services, promotions, including marketing communications that we believe might be of interest to you;
  • To communicate with others using the contact information you provide, such as when you designate another person as the recipient of a message;
  • To address problems and improve our products, services and technologies, and to develop new products and services;
  • To deliver consistent personalized services across all our channels, including customizing our ads, marketing communications, and promotional offers;
  • To organize local events;
  • To prevent, detect, mitigate and investigate fraud, security breaches and activities that are or may be banned or illegal;
  • To implement our terms of use or other policies;
  • Considering that it is necessary or appropriate to protect the rights, property, safety and security of the company, its employees, customers and others;

As we believe is necessary or appropriate under the applicable law, respond to requests from government authorities and comply with the legal process.

5. HOW DO WE STORE PERSONAL DATA?

We store your personal data as long as it is necessary to provide the services you have requested or for other essential purposes such as compliance with legal obligations, resolution of disputes and implementation of our agreements. Because these needs may vary depending on the different data types in the context of different products, actual retention periods may vary significantly. The criteria used to determine retention periods include:

  • Maintaining and improving product performance, maintaining our systems safely, and maintaining appropriate business and financial records.
  • The period for which you have expressed your consent or until you express your intention in one of the ways set forth in this policy to not keep them;
  • If it’s data that you have access to, the data will be stored until you delete it. For example. deleting your account from our site. If your data is considered sensitive, it will be stored for a shorter period;
  • A situation in which a law requires the retention of personal data to maintain data relevant to an investigation or data to be retained in the event of a dispute.

The storage times of your personal data vary according to the purpose for which they are used as follows:

  • The purpose of providing you access to the platform – as long as you maintain your account with footballcoin.io
  • The purpose of marketing and advertising –

6. WHERE ARE WE TRANSMITTING PERSONAL DATA?

Your personal data may also be processed by other Controllers, associate Controllers or authorized agents of the Controller, with due respect for the legislation on the protection of personal data:

  • IT service providers as well as all companies in these categories of recipients from whom the Controller will contract services and products and have taken appropriate protective measures as required by law to ensure that they comply with their obligations of protection of personal data. If the empowered persons subcontract part of the activities involving the processing of personal data, the subcontractors will be subject to the same obligations regarding the implementation of the security, technical and organizational measures foreseen by the EU General Regulation on Data Protection, but also of the internal normative acts approved for the implementation of the EU General Regulation;
  • The contracting parties of the Controller who are associated controller, in order to perform outsourcing services;
  • State authorities on the basis of their competencies provided by the applicable law;
  • We can share your information with our service providers who handle customer information and who perform services on our behalf, such as making promotions, sending messages to customers, conducting surveys, etc. We have not authorized any of these service providers to perform other operations with your information;
  • We can share your information when working with another company to offer or provide our users with products, services, contests or promotions;
  • We may share information about you if necessary or appropriate, in good faith, to comply with laws or regulations or to respond to a valid quote, government order or request or to protect operations, privacy, safety, property or the Controller’s rights;
  • In the unlikely event of a sale or merger of the Company, the personal information of our clients and other information we have collected as described in this policy may be among the transferred assets.

Your data will not be transferred abroad. If your data will be transferred to other companies / entities in other countries outside the EU / EEA, you will be informed accordingly.

7. HOW DO I CHOOSE THE PROMOTIONS I RECEIVE?

Our company only want to communicate with you if you want to hear from us. If you prefer not to receive promotional information such as information about special offers and sales events from one or more brands, you can let us know by contacting our customer service as described in the section titled “How to contact us? ‘

8. HOW DO WE PROTECT CHILDREN’S DATA?

We are concerned about children’s privacy and safety when using the Internet. We will never knowingly ask for online personal identification information from people who do not have reached the age of 16 without verifiable parental consent. Our sites are general audiences and are not targeted or intended for children.

9. WHY DO WE COLLECT OTHER DATA?

Our website uses cookies or similar technologies to provide the best experience for you and to analyze trends, manage the website, track customer use within the website, and collect demographic information about the base users as a whole. Cookies are small text files that are placed on the client’s device to track usage and record preferences. Our cookies do not contain information that can identify people. We collect certain automated information using cookies and tracking technologies such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), page references / outputs, pages viewed on our site (eg HTML pages, graphics), operating system, date / time and / or clicks to analyze the trend as a whole and administer the site. Site users can control the use of cookies at the browser level, but if the user decides to disable cookies, this action will cause some features and features to be limited to our website and services. A useful resource for information on deleting and controlling cookies can be found at AboutCookies.org.
A breakdown of how we use cookies in the relationship with the user can be found in the Cookies Policy section.

10. HOW IS MY INFORMATION USED ON ADVERTISING AND WHAT ARE MY OPTIONS?

We use our own cookies to determine which of our ads are shown on other websites. To opt out of this targeted online advertising using our cookies, click here.

We also work with third-party companies that use tracking technologies (including cookies and pixel tags) on our sites to provide personalized advertising on our behalf and on behalf of other advertisers on the Internet. These companies can collect time information about your activity on our sites and other sites, as well as about your interaction with our advertising and other communications and use this information to determine what ads you see on sites and apps third party. These technologies and the information you collect about you can also be used to track your activity on multiple devices. For more information about this practice and to understand your choices, including how to opt-out of receiving these personalized ads, visit http://www.aboutads.info.

Keep in mind that, whether you give up on them, these tracking technologies can still collect data and you will still see ads, but they will not be targeted based on the information gathered through these tracking technologies.

11. WHAT MEASURES OF SECURITY HAVE WE ADOPTED?

We guarantee that your data processing is carried out under legitimate conditions, while implementing appropriate technical and organizational measures to ensure the integrity and confidentiality of the data under the Regulation.

The company has implemented a personal data security policy that is confidential for security reasons. We ensure that your data is processed by trained personnel to the highest standards of confidentiality.

When you enter your personal information on our sites, we use encryption technology to protect your information as it is transmitted to us.

12. WHAT IS PHISHING?

“Phishing” is a scam designed to steal your personal information. If you receive an email that appears to be from us, asking for your personal information, you are not responding. We will never ask for your password, username, credit card information or other personal information by email.

13. WHAT LINKS TO OTHER SITES WE HAVE?

Our sites may contain links to other sites, which may have privacy policies that differ from their own. We are not responsible for the content or practices of a linked site. We recommend that you review the privacy policy of any site you visit through our sites.

14. HOW TO ACCESS OR CHANGE THE INFORMATION WHICH YOU HAVE NOT TRANSMITTED?

You may review and modify certain personal information necessary for your use of our online sites.
You can also ask us to update your personal information by contacting us as described in the section entitled “How can you contact us?” Below. Please note that any request to update your personal information may take up to 10 days for your emailed request and for 6-8 weeks for your request through classical postal services.

15. HOW CAN YOU CONTACT US?

For questions about privacy policy, to make choices for receiving promotional communications, to update your personal information, you can contact us by  e-mail: dpo@footballcoin.io

16. WHAT ARE YOUR RIGHTS?

According to the legislation on the protection of personal data, you have the following rights: the right to information, the right of access to data, the right to rectification, the right to delete the data (the right to be forgotten), the right to restrict the processing, data portability, the right to opposition, and the right not to be subject to an individual automated decision, including the creation of profiles.

For further details on the processing activities carried out by Foo, and about the rights you enjoy in this context, please e-mail us to dpo@footballcoin.io

Your request will be reviewed and will be answered within 30 days of receipt of the request by the Controller. In the case of complex or very large requests, this period may be extended by two months.

You are also entitled to apply to the Personal Data Processing Supervisory Authority (ANSPDCP), based in G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, in the form of a written address at the headquarters of the institution or by e-mail at anspdcp@dataprotection.ro You are also granted the right to address to the defense any rights guaranteed by the applicable law in the field of personal data protection that have been violated.

DATA PROTECTION OFFICER CONTACT DETAILS

You can contact the Data Protection Officer named by the Company:

Valentin Marin

E-mail address: dpo@footballcoin.io

Crowngem Limited 

BVI Incorporation No. 468405

Registered Office: Palm Grove House, Box 438, Road Town, Tortola, VG1110 British Virgin Island