PRIVACY NOTICE ON PERSONAL DATA PROCESSING RELATED TO THE FACEBOOK AND INSTAGRAM PAGES OF THE GAME TSAK

This Privacy Notice aims to provide you with information about what personal data AIBEK EOOD processes during your visit to and like/following the official Facebook and Instagram pages of the game Tsak (hereinafter “TSAK”) as well as why and how these data are used.

If you have any questions, you may contact us via e-mail: office@tsak.games or at a postal address 24G „Gen. Ivan Kolev“ str., mailbox №20 , Sofia 1407.

INTRODUCTION

The game TSAK is developed, produced and distributed by AIBEK EOOD as company owner of all IP rights related to the game.

Facebook (http://www.facebook.com/tsak.games/) and Instagram (http://instagram.com/tsak.games) pages of the game TSAK (hereinafter “the Facebook and Instagram Pages”) are created to facilitate the communication between us, the game creators and you – its users and fans, as well as for the promotion of new goods, services, games, discounts campaigns and events organized by us or our partners in relation to TSAK. Our Facebook and Instagram Pages also aim to provide you with the opportunity to share your opinion, feedback, assessment and experience with TSAK and all products related to the game.

For the performance of the activities mentioned above, AIBEK EOOD processes personal data of the following main categories data subjects:

• VISITORS OF THE FACEBOOK AND INSTAGRAM PAGES OF TSAK
• INDIVIDUALS PARTICIPATING IN GAMES ORGANIZED IN FACEBOOK AND INSTAGRAM PAGES OF TSAK
• INDIVIDUALS ATTENDING EVENTS ORGANIZED IN RELATION TO TSAK

HOW, WHY AND WITHIN WHAT TIME LIMITS DO WE PROCESS YOUR PERSONAL DATA

AIBEK Ltd. with UIC 204877283, having its seat and address of management at Garlo Village No. 100, postal code 2381, Pernik District, Breznik, Bulgaria, represented by Konstantin Vaskov Popov (hereinafter referred to as “AIBEK” and the “Controller”) in its capacity of personal data controller processes the following personal data:

VISITORS OF THE FACEBOOK AND INSTAGRAM PAGES OF TSAK

We from AIBEK process the following categories personal data of the visitors of our Facebook and Instagram pages

(a) data, contained in their profile in the respective social media, for example: names, gender, address, e-mail address, telephone number, date of birth; data contained in pictures, video records, voice records, in case and to the extent that the visitor has shared publicly these data in his/her profile;

(b) other data, published in the Facebook page of TSAK by the visitors, namely: photos, videos, comments, personal messages and all other types of posts made by the visitor in our Facebook/Instagram Page.

Purpose, legal basis and processing terms

We use the data above only for the following purposes:

• administration and management of the Facebook and Instagram Pages of TSAK;
• administration of any comments and complaints of our customers made through our Facebook/Instagram Pages

We process these data on the basis of our legitimate interest to popularize and advertise the game TSAK and all of our other products and services related to it.

When you publish information or upload pictures/videos at the Facebook/Instagram Pages or post a comment to any of our posts, the information you have published and your Facebook identification name become publicly available. This information could be accessed by anyone who is visiting the Facebook/Instagram Pages of TSAK.

We are not responsible for the way these third parties use the information you posted on our Facebook and/or Instagram Pages.

When you participate in discussion on our Facebook and/or Page (including through personal messages), we strongly recommend that you avoid sharing personal data that can be used to identify yourself directly, such as your name, age, address, and phone.

We are not responsible for the protection of the information you have posted on the Facebook or Instagram Pages of TSAK.

The processing term for these purposes is until the deletion of the specific article or post.

INDIVIDUALS PARTICIPATING IN GAMES ORGANIZED IN FACEBOOK AND INSTAGRAM PAGES OF TSAK

AIBEK may processes the following categories personal data of individuals who registered themselves to participate in games, organized by us (including such organized by us together with our partners) in the Facebook and/or Instagram Pages of TSAK:

(a) data for physical identity: first name and family name; gender; email address; telephone number; address;

(b) data related to games’ participation: data contained in photos and/or videos; comments and other social media posts.

Purpose, legal basis and terms of the processing

We may use the data above only for the following purposes:

• administration of games and events, including contacting the winning participants, awarding prizes, conducting mandatory accounting and taxation;
• we may also (but not necessary) use the above personal data for direct marketing of any activities, initiatives and campaigns and other events organized in relation to the game TSAK including such organized by our partners.

We process these personal data on the basis of our legitimate interest to promote and advertise the game TSAK and any other products and services created in relation to the game, as well as on the basis of our contractual obligation to award prizes to the winning participants.

The processing of your personal data for these purposes is limited by the following terms:

• for the purposes of administering the specific campaign/event your personal data will be processed for a maximum of 7 (seven) days after the expiration of the term for receiving the awards from the game (including in paper form);
• data contained in documents, necessary for the execution of contracts – up to 6 (six) years after termination of the respective contract or until closure of dispute related procedures;
• data contained in accounting registers and financial statements and/or data contained in documents subject to tax audits and needed for accounting purposes – up to 11 (eleven) years.

Information how to exercise your right to object to direct marketing, can be found in the What Are Your Rights section below.

INDIVIDUALS ATTENDING EVENTS ORGANIZED IN RELATION TO TSAK

AIBEK also processes the following categories personal data of individuals who have attended events, organized in relation to the game TSAK:

(a) data for physical identity: data contained in photos and/or videos.

Purpose legal basis and terms of processing

AIBEK may post on its Facebook and/or Instagram Pages of TSAK photos and/or video records of events organized in relation to the game – e.g. tournaments, public representation of the game, etc. These events might be held offline and online.

The processing of your personal data in this case is based on our legitimate interest to promote the organized events and communicate their conduct.

If you do not want photos/videos of you to be published on our Facebook/Instagram Pages, you have the right to object to the processing of these data and we will ensure that the respective posts are removed from the Facebook/Instagram Page respectively.

Information on how to exercise your rights, including how to object, can be found in the What Are Your Rights section below.

The term of this processing is until the specific article or post is deleted.

WHO WE CAN SHARE YOUR DATA WITH

AIBEK may assign any of the above-mentioned activities of personal data processing to marketing agencies and IT service providers (including such providing software and hardware solutions) ensuring data protection and lawful processing. We may also provide personal information to our partners, if this is necessary for the provision of game prizes (including couriers and co-organizers of games).

WHAT ARE YOUR RIGHTS

If you are an individual whose data are processed by the Controller under any of the above circumstances, you have the following rights with this regard:

(a) You have the right to object to processing of your personal data for the purpose of:

(1) promoting events organized in relation to the game TSAK in our Facebook and Instagram Pages;
If you make such an objection to a publication of photos/videos containing your personal data on the Facebook/Instagram Pages, we will remove the respective photos/videos and will no longer process these personal data for that purpose.

(2) direct marketing, if you are addressee to such messages
If you make such an objection to our direct marketing messages we will no longer process your personal data for this purpose but none of our other services provided to you will be limited anyhow. However, in order to ensure that your objection is regarded, your data will be included in data base of objected data subjects.

(b) All data subjects have the following rights:

(1) be informed what kind of personal data are processed by the Controller;

(2) access and receive a copy of their processed personal data;

(3) rectification or erasure of their personal data;

(4) restrict the processing; and 

(5) data portability.

You may exercise any of your rights above by submitting a written application in any of the following ways:

(1) via e-mail to: office@tsak.games 

(2) via letter addressed to: postal address 24G „Gen. Ivan Kolev“ str., mailbox №20 , Sofia 1407

(3) you may also object to direct marketing in any other way indicated by us in the respective direct marketing message – e.g. by clicking on link provided.

You also have the right to file a complaint concerning the processing of your personal data with the supervisory authority which is the Personal Data Protection Commission for the Republic of Bulgaria, with contact details listed in the following link: https://www.cpdp.bg/?p=pages&aid=5

CONTENTS OF YOUR APPLICATION

Please note that your application for exercise of any of your rights should contain at least your names and other identification information, description of your request, preferred way of communication with you, address for correspondence and date of the application.

If the application is signed by a proxy, the respective power of attorney should be attached to the application.

The Controller may contact you for additional information, if it needs to ensure your identity or further clarify your request.

EXCESSIVE DATA PROVIDED BY/FOR YOU

If we receive any personal data in excesses of what is needed for us to comply with our purposes above, we will delete this information immediately but not later than 1 (one) month after its receipt.  

PROTECTION OF YOUR DATA

To help protect the privacy of data and personally identifiable information, we maintain physical, personal, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data only to those employees and personal data processors who need to know that information to provide benefits, goods or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to ensure our employees’ privacy responsibilities

USE OF THE FACEBOOK AND INSTAGRAM PAGES OF TSAK

Like any Facebook and Instagram page, ours also follows the general rules on personal data protection that Facebook and Instagram provides.

With this regard, we want to remind you that the information you share through your Facebook/Instagram account is automatically owned by Facebook Inc. or the Irish subsidiary Facebook Ireland Limited. Facebook has the right to process and store this information until you delete your account.

At the same time, Facebook does not allow companies managing Facebook and Instagram pages to specify storage terms for the information you send them through messages. Thus, sending information via personal message to the Facebook/Instagram Pages of TSAK implies higher risks for your personal data as we could not guarantee where and how long your personal data are stored.

For this reason, each data subject has the freedom to provide us with information through alternative means which are under our control, for example by email to: office@tsak.games 

CHANGES AND UPDATES TO THIS PRIVACY NOTICE

As our organization, goods and services change from time to time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice. We may e-mail periodic reminders of our notices and terms and conditions and will e-mail our clients and partners of material changes thereto, but you should check our pages frequently to see the current Privacy Notice that is in effect and any changes that may have been made to it.

The present document represents privacy notice within the meaning of Art. 13 and Art. 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).