Privacy Policy

Privacy Policy will be effective from January 01, 2023.

Your privacy is and will always be enormously important to us. Please read it carefully, because it is important for you to understand what we do with your information and how you can control it.

INTRODUCTION

Our Privacy Policy explains how your personal data provided by you and/or received by us ('personal data' or 'personal information') are collected and processed by GLERA GAMES APPS LIMITED ('we', 'our' or 'us'). Our Privacy Policy also explains your legal rights in respect of your personal data. Our Privacy Policy applies to our website – glera-games.com (the “website”).

CONTACT US

GLERA GAMES APPS LIMITED is a company incorporated on Cyprus which is a controller of your personal data. If our Privacy Policy doesn't contain the information you need or if you experience problems related to your personal data, please feel free to contact us, and we will get back to you as soon as practically possible. You may contact us: via email at: [email protected], or by mail: Archiepiskopou Makariou III, 169, CEDAR OASIS TOWER, office 701, Limassol, 3027, Cyprus. Please note that for the exercise of some of your data subject rights, we might be requested by law to verify your identity.

THE PERSONAL DATA WE COLLECT, OUR PURPOSES AND LEGAL BASES FOR DATA PROCESSING

When collecting and processing your personal data, we are striving to be as transparent as possible, thus consider checking the list of personal information that we collect and process. Generally, we process your personal data to provide you access to the website, to ensure proper and secure functioning thereof, to comply with applicable laws and regulations, and to enhance your experience while using the website. We also use your personal data to contact you when necessary. We do not and will not process your personal data in order to sell it.

#PURPOSES	#LEGAL BASIS	#PERSONAL DATA
to provide our website to you	to provide our website to you	technical information regarding interaction with website
to answer general questions sent to our emails	our legitimate interest to improve and optimize our website and maintain and prove our relations with visitors	email, any additional information provided by you in the email when contacting us
to improve and optimize our website and our website visitors' experiences, review our website visitors' viewing patterns and the effectiveness of our websit	our legitimate interest to improve and optimize our website and our website visitors' experiences	technical information regarding interaction with website
to consider an application for a vacancy submitted through our website	on the basis of your consent to such processing	potential employee's data (full name, email, city, CV or portfolio, contact phone, link to Telegram, any additional information provided by you in the 'Apply for a vacancy' field)

WHERE DO WE GET YOUR PERSONAL DATA FROM

Device Data

We automatically receive device-specific and device event information from the devices you use to in order to get access to the website.

Personal data you provide us directly.

We receive your personal data that you directly provide to us while using the website or include it in an email or other messages that you send to us.

Third parties' data.

We may receive your personal data from the third parties if you have given your consent to such third parties to provide us with your personal data or if you make these data public on your own.

DO WE COLLECT YOUR PAYMENT INFORMATION?

We do not and will not collect or process any information related to your payment instruments, such as your credit card number, its expiration date or your name as written on your card.

CHILDREN'S PRIVACY

We recognize that we have a special obligation to protect children's data. We do not knowingly collect children's personal data. If you are aware that we unintentionally process children's personal data, please contact us and we will make all reasonable efforts to stop processing such data and erase it as soon as possible. We will delete this data in accordance with applicable law.

AUTOMATED DECISIONS

We neither use automated decision-making nor your personal data to automatically assess aspects of your personality (automated profiling).

HOW WE PROTECT YOUR DATA

We maintain appropriate administrative, technical and physical security measures to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. We can also anonymize your personal data as soon as we do not need it anymore. Anonymisation is the process of removing personal identifiers, both direct and indirect, that may lead to an individual being identified. The result of this process is anonymous data that cannot be associated with any individual.

HOW LONG DO WE STORE YOUR PERSONAL DATA

We process all the collected data for 24 months. After the expiry of this time limit, we erase your personal data from our database or anonymize it, as well as request same erasure from any third parties whom your data may have been transferred to. We can also delete or anonymize your personal data as soon as we do not need it anymore. All data submitted through the “Apply for a vacancy” field will be stored and processed according to the Privacy notice for job applicants of Glera Games.

WITH WHOM WE SHARE YOUR PERSONAL DATA

Affiliates.

We may share your personal data with subsidiaries, affiliates, and companies under common control with Glera Games Apps Limited.

Law enforcement or government bodies.

In order to combat fraud and illegal activity, situations involving potential threats to the physical safety of any person or as required by law, we may process and disclose data with law enforcement or government bodies in response to lawful requests.

Third-party service providers.

We may provide third parties with your data on our behalf since their respective technical solutions may form an integral part of the website. Standard Contractual Clauses are used to share your personal data to ensure that they are properly protected. You can learn about the procedure for handling the personal data of our third-party service providers at the following links:

• Google LLC (Google Analytics) -https://policies.google.com/privacy?hl=en&gl=by
• Helpshift, Inc. -https://www.helpshift.com/legal/privacy/
• Huntflow AM LLC - https://huntflow.ai/docs/privacy-policy

INTERNATIONAL TRANSFERS OF PERSONAL DATA

Our website is global, and your personal data can therefore be transferred to anywhere in the world. We apply the Standard Contractual Clauses approved by the European Commission or other appropriate means as legal mechanisms for any such transfer, and make sure that such transfers occur only if there are adequate safeguards in place. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in the country of your residence. By using our website or providing us with any information through them, you acknowledge such transfer, processing, and storage of your personal data in countries in which privacy regulations may be not as comprehensive as those in the country of your residence.

YOUR RIGHTS AND OPTIONS UNDER THE GDPR

You have certain rights in connection with your personal data and how we handle it. We allow all visitors to submit the requests by sending an email to [email protected].

Right to access your personal data.

Under art. 15 of the GDPR, individuals have a right of access that gives them the right to obtain a copy of their personal data, as well as other supplementary information. It helps individuals to understand how and why companies are using their personal data and check the lawfulness of the processing.

Right to rectify (correct) your personal data.

Under art. 16 of the GDPR, individuals have the right to have inaccurate personal data rectified. An individual may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing.

Right to have your personal data erased (deleted).

Under art. 17 of the GDPR, individuals have the right to have personal data erased. This is also known as the ‘right to be forgotten'. The right is not absolute and only applies in certain circumstances.

Right to object to processing of your personal data.

Art. 18 of the GDPR gives individuals the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organization uses their data. This is an alternative to requesting the erasure of their data.

Right to transmit your personal data.

Under art. 20 of the GDPR, individuals have the right to data portability that gives individuals the right to receive personal data they have provided to a controller in a structured, commonly used and machine-readable format. It also gives them the right to request that a controller transmits those data directly to another controller.

Right to restrict processing of your personal data.

Art. 21 of the GDPR gives individuals the right to object to the processing of their personal data at any time. This effectively allows individuals to stop or prevent you from processing their personal data.

Right to withdraw your consent for personal data processing.

Art. 7 (3) of the GDPR gives individuals the right to withdraw their consent for personal data processing. Any withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority.

In accordance with art. 77 of the GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, VIRGINIA

If you are a resident of California or Virginia, you are entitled to the following rights with respect to your personal data:

The right to know.

You may submit twice a year, free of charge, a verifiable request to disclose what personal information we collect about you:

• categories of personal data collected;
• categories of sources of personal data;
• categories of personal data about you we have disclosed for a business purpose or sold;
• categories of third parties to whom we have sold or disclosed for a business purpose your personal data;
• the business or commercial purposes for collecting or selling personal data;
• a copy of the specific pieces of personal data we have collected about you.

Right to correct.

You have the right to request us to correct inaccurate personal information about you.

Right to opt-out.

You have the right to opt-out of “sale” of your personal information, as defined by the CCPA.

The right to request the deletion of your personal information.

You have the right to request that we have collected about you and to have such personal data deleted (without charge), subject to certain exceptions (such as, including but not limited to, where the information is used to identify and repair errors on website, to detect security incidents and protect against fraudulent or illegal activities, etc.).

Right to non-discrimination.

We may not discriminate against you for exercising any of your rights, including, but not limited to, by denying goods or services to the resident; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to the resident; suggesting that the resident will receive a different price or rate for goods or services or a different level or quality of goods or services.

DATA DISCLOSURE AND/OR SALE (FOR RESIDENTS OF CALIFORNIA, VIRGINIA)

We do not “sell” your personal data with third parties and businesses for commercial purposes, but we share certain information with third parties who do work on our behalf. We have shared the following categories of personal data as part of our Services:

#PERSONAL DATA	#CATEGORIES OF THIRD PARTIES TO WHOM WE MAY SHARE PERSONAL DATA
technical information regarding interaction with website	Affiliates and Subsidiaries. Service Providers (Google LLC (Google Analytics)
email, any additional information provided by you in the email when contacting us	Affiliates and Subsidiaries. Service Providers (Google LLC (Google Analytics)
potential employee's data (full name, email, city, CV or portfolio, contact phone, link to Telegram, any additional information provided by you in the 'Apply for a vacancy' field)	Affiliates and Subsidiaries. Service Providers (Google LLC (Google Analytics)