PRIVACY NOTICE ON PERSONAL DATA PROCESSING HELD BY AIBEK EOOD
This Privacy Notice aims to provide information regarding the nature of your personal data processed by AIBEK EOOD in relation to the production, distribution, sales and the marketing of the game TSAK and all products related to it. If you have any questions with this regard, please contact us via e-mail: office@tsak.games or at a postal address 24G „Gen. Ivan Kolev“ str., mailbox №20 , Sofia 1407

INTRODUCTION
AIBEK EOOD is a company that created developed, produces, advertises and distributes directly or through intermediaries the game TSAK and all related products (together referred to as “TSAK”). The Company also develops and provides to its clients the online shop www.tsak.games for direct sales of TSAK.

I. CATEGORIES OF CONCERNED INDIVIDUALS (DATA SUBJECTS) AND PURPOSES OF DATA PROCESSING
For the performance of its main activity for distribution, direct sales and marketing of TSAK, AIBEK EOOD (еxcept from its internal corporate and employment relations) processes personal data of the following main categories of data subjects:
• CLIENTS (CUSTOMERS) OF TSAK
• INDIVIDUALS ADDRESSEES TO AND/OR PARTICIPATING THE GAMES, PROMOTIONS AND OTHER MARKETING CAMPAIGNS ORGANISED BY AIBEK EOOD
• LEGAL AND/OR AUTHORIZED REPRESENTATIVES AND CONTACT PERSONS OF THE CONTRACTORS OF AIBEK EOOD
• BUSINESS CONTACTS

II. HOW, WHY AND WITHIN WHAT TIME LIMITS DO WE PROCESS YOUR PERSONAL DATA
The below information is concerned to both data subjects who provided their personal data to AIBEK EOOD by themselves as well as those whose personal data has been provided to AIBEK by third parties (e.g. by their employers).

AIBEK EOOD 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 the “Controller”, “AIBEK” or the “Company”) in its capacity of personal data controller process personal data as follows:

• CLIENTS (CUSTOMERS) OF TSAK
In this item you may find more information on what personal data and how we process them in relation with the sale of TSAK, including and not limited to sales through the online shop www.tsak.games. With this regard we process the following categories of data:

(i) individuals, clients of the online shop www.tsak.games and individuals purchasing the products of AIBEK in other way including and not limited to offline or through online platforms-intermediaries;
(ii) legal representatives of our clients legal entities;
(iii) authorized representatives of the individuals per item (ii) above;
(iv) individuals for contact with our corporate clients, together referred to as “Clients”.

We from AIBEK process the following categories personal data of the individuals our Clients
(a) data for physical identity: name, address, telephone number, electronical address, IP address, date of birth.

NB: AIBEK does not process personal data for economical identity (number of bank account, credit card, etc.). The same are provided directly from the Client to the respective payment service provider to which web page our online shop refers at the respective stage of each order and we do not have any access to these data and only receive payment confirmation. The processing of these personal data of you is made entirely by the respective payment service provider which should inform you personally about what personal data of you and how it processes and how it protects them. The service provider bears alone full liability for this processing as the only controller of these data.

Please also note that if you contact us for any reason related to an order that you made through our web page www.tsak.games we will make a verification in order to identify you and make sure that you are the person who made the respective order which wants to discuss, change, etc. This verification most probably would require you to provide one or few of your personal data, provided in the order already. The data provided for verification will not be recorded.

Purpose, legal basis and time limit of processing
We may use the data above only for the following purposes:

• Ordering, receipt and performance of clients orders for purchase of goods from online shop www.tsak.games and in other ways including but not only offline or through online platforms-intermediaries;
• Negotiation with clients, potential clients and other contractors of the Company for the purposes of provision of goods and services;
• Client services including responces to inqueries regarding products, distribution, terms of purchase of delivery, returns, etc.
• Control over the performance of contractual and pre-contractual relations;
• property management;
• debt collection;
• accounting and taxation including invoicing;
• administration of and protection of legal claims.

The legal basis for this processing is the performance of pre-contractual and contractual obligations of AIBEK in relation to online and offline sales of goods and any other related obligations.

You may find more information on how you may exercise your rights with this regard in Section III What Are your Rights below.

The time limits for the processing of your personal data for these purposes is as follows:

• data contained in accounting registers and financial statements: 11 years;
• data contained in documents subject to tax audits and needed for accounting purposes: 11 years;
• data contained in documents needed for the performance of contractual relations: up to 6 years after the performance of the last order of the respective individual or until closure of dispute related procedures,

except for the cases when a law, juridical act, contract or commercial practice require other terms.

• INDIVIDUALS ADDRESSEES TO AND/OR PARTICIPATING THE GAMES, PROMOTIONS AND OTHER MARKETING CAMPAIGNS ORGANISED BY AIBEK EOOD
With regards to the promoting of our products and activities we process personal data of the following individuals:

(i) Clients of online shop www.tsak.games and individuals buying our products in other way including but not limited to offline sales or through other online platforms-intermediaries;
(ii) Individuals participating in online or offline campaigns, eveins, tournaments and others similar events organized by AIBEK and/or jointly with its partners in relation to the goods and services provided by us;
(iii) Individuals who liked or followed the profiles administrated by AIBEK in the social media Facebook and Instagram and/or participated in games or other marketing campaigns organized by us.

The categories personal data of the individuals listed above processed by AIBEK are:

(a) data for physical identity: names, gender, address, e-mail address, phone number, signature, data contained in pictures, video records, voice records, comments or other posts in social media;
(b) data processed in relation to a game or other marketing event: the data above as well as data contained in pictures, video records, comments or other posts in social media in relation to the respective game/event (for more information about the data that we process in relation to Facebook and Instagram pages of TSAK game, please see section Notes in our Facebook page where our privacy notice with this regard is published).

Purpose, legal basis and time limit of processing

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

• administration of games, promotions and other marketing campaigns organized by us and addressed to the categories of individuals above, including for delivery and reporting of awarding prizes, conducting mandatory accounting and taxation;
• administration and maintenance of our web page and the Facebook and Instagram pages of the game TSAK;
• we may also (but not necessary) use the above personal data for addressing direct marketing messages for any activities, initiatives and other events organized in relation to the game TSAK, including such organized by our partners;
• research of the feedback of clients and potential clients by sending them invitation for participation in different marketing researches;
• accounting and taxation in case of giving awards from promotional games and other marketing campaigns.

Legal basis of the processing
We processes these personal data on the legal basis of our legitimate interest to promote and advertise the game TSAK and any other products and services created in relation with the game, as well as on the grounds of our contractual obligation to award prizes to the winning participants in case of organized games.

The time limits for processing your personal data for these purposes are as follows:

• for the purposes of administering the specific campaign/event your personal data will be processed for a maximum of 7 days after the expiration of the term for receiving the awards from the game (including in paper form);
• for direct marketing purposes, the data are stored in marketing databases and the data storage term is 10 years after the end of the marketing campaign in which the data were collected;
• data contained in documents, necessary for the execution of contracts – data contained in documents needed for the execution of contractual obligations – up to six years after termination of the respective contract or until closure of dispute related procedures;
• data contained in accounting registers and financial statements or data contained in documents subject to tax audits and needed for accounting purposes – 11 years

except for the cases when a law, juridical act, contract or commercial practice require other terms.

• LEGAL AND/OR AUTHORIZED REPRESENTATIVES AND CONTACT PERSONS OF THE CONTRACTORS OF AIBEK EOOD
AIBEK processes the following categories of personal data of its contractors:

(a) the minimum amount of personal data necessary for the signing of the respective contract – names, Personal Identification Number and signature. Identity Card data are only used where the contract is signed with notary verification or by a representative authorized via notarized power of attorney;
(b) personal data for business contact in the course of contract performance – this information is limited to the types of information which could be contained in business cards/electronic signature, including in e-mails: name and surname, position, name of employer, business address, business email address and business phone number;
(c) for social identity – professional qualification when it is necessary for the performance of activities requiring special qualification.

We receive from our Contractors the above listed personal data (contact information) of employees or other individuals assigned by our Contractors as contact persons for the respective contract. Our Contractors providing us these data are also personal data controllers of these data and are responsible to provide the respective Data Subjects with all needed information with this respect. Furthermore, our Contractors are obliged to ensure the accuracy of these data and for keeping them up-to date all the time. This means that if any data provided to us is changed or no longer accurate, we need to be duly informed on this as soon as practically possible. Until receiving such notice, we assume that the provided contact related data are accurate and we may use it for the purposes below.

Purpose, legal basis and time limit of processing

We use the above data only for the following purposes:

• performance of pre-contractual and contractual obligations, execution and administration of contracts (including accounting and taxation), control over the performance and debt collection, protection against legal claims.

The legal basis for this processing is the performance of pre-contractual and contractual obligations and our legal obligation for accounting and taxation. A legal basis is also our legitimate interest to provide goods and services to end-customers through contractors providing goods and services and/or are intermediaries.

The personal data mentioned in this section are processed in the following time limits:

• data contained in accounting registers and financial statements: 11 years;
• data contained in documents subject to tax audits and needed for accounting purposes: 11 years;
• data contained in documents needed for the performance of contractual relations: up to 6 years after termination of the respective contract or until closure of dispute related procedures;
• data processed in relation to the compliance with statutory obligations – within the applicable statutory terms.

except for the cases when a law, juridical act, contract or commercial practice require other terms.

• BUSINESS CONTACTS
If you provided any representative of AIBEK with your business contact information via your business card or in any other way or this information is publically available, please note that it is possible that we have included this information of you in our business contacts list.

The above means that in case of business need, for the purpose of sending you holiday greetings or for the purpose of providing you with information about our services, events etc. We may contact you with this regard but only in your official capacity in which we have your contact information. AIBEK provides all necessary protections to its database with business contacts as for all other personal data. If you do not wish AIBEK to contact you as described above, please inform us at any of our addresses listed in the next Section III and your contact information will be deleted from our business contacts database.

AIBEK provides all necessary protections to its database with business contacts as for all other personal data.

If you do not wish AIBEK to contact you as described above, please inform us at any of our addresses listed in the next Section III and your contact information will be deleted from our business contacts database.

III. WHAT ARE YOUR RIGHTS
If you are a person, whose personal data are processed by the Controller under any of the above circumstances, you have the following rights in this regard:

(a) you have the right to object to the processing of your personal data for the purposes of direct marketing messages and campaigns/games, if you are an addressee to direct marketing or participate campaign/games. If you make such an objection against direct marketing, we will no longer process your personal data for this purpose. However, in order to ensure that your objection is regarded, your data will be included in data base of objected against the respective processing;
(b) all data subjects have the right:

• to be informed about the types of personal data processed by the Controller;
• to access to and copy of their processed personal data;
• to correct or erase their personal data;
• to limit processing;
• to portability.

You can exercise and of the abovementioned rights by submitting a written request, in either of the following ways:

• by e-mail to: office@tsak.games
• by mail addressed to AIBEK Ltd., UIC 204877283, address for correspondence 24G „Gen. Ivan Kolev“ str., mailbox №20 , Sofia 1407 represented by Konstantin Vaskov Popov;
• you may also object to direct marketing by other means, as specified in the respective marketing message – for example, through following a link provided in an email.

You also have the right to complain regarding the processing of your personal data to the relevant authority, which for the Republic of Bulgaria is the Commission for Personal Data Protection with contact details: 2, Prof. Tsvetan Lazarov blvd., Sofia 1592; kzld@cpdp.bg; fax 029153525.

IV. CONTENTS OF YOUR APPLICATION
Please note that your application for exercise of any of your rights should contain at least your names with other identification information about you, description of your request, preferred way of communication with you, address for correspondence, signature and date of the application. If the application is signed by a representative, the respective power of attorney should be attached to the application. We may contact you for additional information, if it is needed to ensure your identity or further clarify your request.

V. WHOM WE CAN SHARE YOUR DATA WITH
We may assign any of the abovementioned personal data processing activities related to direct marketing or games to marketing agencies and IT service providers, in the course ensuring the protection of data and its lawful processing. We may also provide your personal data to our partners, where necessary (for example to a couriers and co-organizers of games for the delivery of the prizes).

The data might also be provided to AIBEK’s shareholder/s, third parties involved in the maintenance and management of our activities, such as our accountants, auditors, lawyers, marketing agencies, IT suppliers and other software and hardware service suppliers as well as to competent authorities if duly requested.

VI. EXCESSIVE DATA PROVIDED BY/ABOUT 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 a month after its receipt.

VII. PROTECTION OF YOUR DATA
To help protect the privacy of your personal data, 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 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 enforce our employees’ privacy responsibilities.

VIII. USE OF THE WEB PAGE WWW.TSAK.GAMES
As is true of most other websites, the website of the game TSAK collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our website, including a history of the subsections you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. The website also uses cookies and web beacons. It does not track users when they cross to third party websites, does not provide targeted advertising to them, and therefore does not respond to Do Not Track (DNT) signals. You may find further information on our cookie policy here.

IX. 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 at this Site. We may e-mail periodic reminders of our notices and terms and conditions and will e-mail our partners and hotel guests of material changes thereto, but you should check our website 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).