«Clean Games» Privacy Policy

1. General conditions
1.1. This privacy statement explains:
  • What personal data is collected by the owner of this web site or provided by you, through our interactions with you and your use of our web site https://cleangames.org, apps and software
  • How your personal data will be used, where it is held, how long it will be kept and your rights.
1.2. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
1.3. For the purpose of the General Data Protection Regulation the data controller is «Clean Games» NGO with company registration number 7819039109 (Taxpayer Identification Number) and the registered address at Shahmatova street 14, k. 24, Petergof, Saint-Petersburg, 198504, Russian Federation.
1.4. Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next visit or log onto the Website.

2. Definitions and interpretation
2.1. In this privacy, the following definitions are used:
  • Data controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
  • Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

2.2. You, your or data subject means:
  • Visitors to our website
  • Subscribers to any service we offer through our site
  • Prospective or existing clients corresponding with us by phone, e-mail or otherwise.

2.3. Data controller, we, us and our means:
  • «Clean Games» IPO and its data processors;
  • personal data means any information relating to an identified or identifiable natural person (data subject);
  • an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation (EU 2016/679).

2.4. Sensitive personal data – special categories of data (according to GDPR).
2.5. Special categories of personal data - means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
3. Rights of users
We would like to make sure you are fully aware of all of your protection rights. You have the following rights in accordance with the General Data Protection Regulation:
3.1. The right to be informed. In this privacy statement we supply you detailed information related to your personal data storage, maintenance and processing.
3.2. The right to access information held about you.
3.3. The right to rectify your personal data if it is inaccurate, incomplete or out-of-date.
3.4. The right to erasure (delete or remove) your personal data..
3.5. The right to restrict (block) processing. When processing is restricted, we will store your personal data, but not further process it;
3.6. The right to data portability is your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another controller from the current controller applicable if: The processing is based on consent or on a contract, and the processing is carried out by automated means.
3.7. Rights related to automated decision making including profiling.
3.8. The right to withdraw your consent or object to direct marketing and other types of processing if applicable. You can exercise your rights by contacting us at: ecologic.game@gmail.com
3.9. The right to lodge a complaint with a supervisory authority, if you have a concern about our information rights practices.
4. Personal data we may collect from you
4.1. Personal Data you provide us voluntarily. You might provide us some personal information by filling in the contact forms on our web, by corresponding with us by phone, e-mail or otherwise or reporting a problem with our Website.
4.2. The information you may provide us is Personally Identifiable Information that identifies an individual or may with reasonable efforts cause the identification of an individual, and may include the following data: first name, surname, address, e-mail address, link to page in social networks and phone number.
4.3. Your message could include your personal data, lifestyle and social circumstances, family detail, education and employment details, special category data, (please see the paragraph Sensitive information and special category data for more details) and information related to fundraising, volunteering or otherwise activities.
4.4. Sensitive information and special category data
4.4.1. Your message might include sensitive information or special category data (please check the paragraph “Definitions and interpretation”) related to your racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, physical or mental health or condition, sexual life.
4.4.2. Submission of this type of information is strictly voluntary. The submission of your enquiry is protected by an industry standard SSL/TLS encrypted connection.
4.4.3. By including special category data in your communication you provide your informed and explicit consent to the transfer, storage and processing of the specified special category personal data for the purposes specified in paragraph “Lawful basis and the purposes of the processing (Uses made of your personal information)”, by us and our Data Processors and subcontractors specified in paragraph “Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data”.
4.5. Children
4.5.1. If you are a child below 16 and wish to tell us something concerning you, you can contact us, call us or visit personally.
4.5.2. If later you wish to modify or delete the information you provided, you can contact us using the contact details below provided in the paragraph “Rights of users”.
4.6. Information you provide about others
4.6.1. In providing personal data about other individuals (such as someone in whose name you are registering an account or subscribing to our marketing promotions), you represent that you have notified them of (i) the purposes for which information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information.
4.6.2. You further represent that You have obtained all necessary consents from them.
5. Lawful basis and the uses made of your personal information
5.1. We process all personal data lawfully, fairly and in a transparent manner. We use the data we collect for the following basic purposes, described in more detail below.
5.2. We process personal information and special category data in order to
  • provide a voluntary service for the benefit of the public as specified in our constitution;
  • to fundraise and promote the interests of the charity;
  • to manage your registration as a user of our services. The personal data you provide can give you access to different functionalities of the services that are available to you as a registered user;
  • to contact you: by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
  • to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information;
  • to manage your requests: to attend and manage your requests to us.
5.3. As the data subject you have the right to withdraw your consent for processing your personal data at any time. Please see paragraph “Your rights”. We may also contact you about our projects, fundraising activities and other ways to support us or communicate with us. The lawful basis for such processing is consent.
5.4. We might use your automatically collected data such as IP address and browser data for our Website improvement, such as:
  • To administer our site and for internal operations, including data security, troubleshooting, testing, statistical purposes;
  • To ensure that content from our site is presented in the most effective manner for you and for your device. The lawful basis for such processing is Legitimate interests.
6. Information which may be made available to us, or collected automatically with the use of cookies or analytic tools
6.1. We might get some information from our visitors by recording how they interact with our Website with the use of cookies, analytics tools or obtain data from third parties.
6.2. This technical information might have included:
  • Device and connectivity information such as IP (Internet Protocol) address, Browser type and version, Language settings, Time zone settings, Browser plug-in types and versions, Pages you viewed or searched for, Full uniform resource locators (URL), Methods used to browse away from the page, Clickstream to, through and from the site (including date and time), Length of visits to certain pages, Page interaction information (such as scrolling, clicks, and mouse-overs), Log information, such as error reports, download errors, any problems users might experience using the web site;
  • Unique device identifiers (such as the IMEI for phones), Location information (ie. GPS) , Mobile phone number, App-based settings, Photos, Camera;
6.3. We do not match information collected automatically through cookies and analytics tools with other personally identifiable information you may have provided to us when you create an account or submit a form through our Website.
7. Storage of personal data
Your data will be stored by us on specially protected servers, which is based in the Russian Federation, in our Customer Relationship Management system and database. These are protected by technical and organizational measures against loss, destruction, access, modification or dissemination of your data by unauthorized persons. Access to your data is only possible for a few authorized persons. These are responsible for the technical, commercial or editorial support of the servers.
8. Cookie policy
8.1. A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device.
8.2. We might use the following cookie types to recognize you when you visit our site or use our Services, remember your preferences and give you a personalized experience:
  • Persistent cookies – expires at a specific date or after a specific length of time. This means that, for the cookie's entire lifespan (which can be as long or as short as its creators want), its information will be transmitted to the server every time the user visits the website that it belongs to.
  • Third-party cookie - belongs to a domain different from the one shown in the address bar. This sort of cookie typically appears when web pages feature content from external websites. We may use them for website analytics and advertising purposes.
  • Strictly necessary cookies - these cookies enable websites to remember choices their users make, for example, user name, language or text size. These cookies are known as functionality cookies and help to improve user experience of a website by providing a more personalized service.
  • Targeting cookies - these are cookies that are used to deliver content that best suits you and your interests. It can be used for targeted advertising, limiting ad serving or measuring the effectiveness of a promotional campaign.
8.3. Usually browsers accept cookies automatically, however you can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed.
9. Do not track preferences
Do not track is a function that allows visitors to opt out from being tracked by websites for any purpose including the use of analytics services, advertising networks and social platforms. Do not track options are available in a number of browsers including: Google, Internet Explorer, Mozilla Firefox, Safari (Desktop), Safari (Mobile), Android Browser, Opera, Opera Mobile etc.
10. Tracking and analytic tools
We use the following tracking and analytic tools:
  • Google Analytics cookies;
  • Yandex analytics;
  • Web beacons.
11. Social media features and widgets
11.1. Our Website might include certain Social Media features and widgets, such as the following: Facebook like; Facebook share; Twitter tweet; Instagram follow; Google+; Youtube; Telegram; Vkontakte features, buttons or other interactive mini-programs (“Social Media Features”).
11.2. These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Website. Please be aware that if you choose to interact or share any Personal Information via such widgets, you are in fact providing it to these third parties and not to us. Your interactions with these third parties are managed by these Social Media policies and not ours. For example, you will not be able to use the “Facebook Like” button if you are not logged in to your Facebook account. Once you use the button this will be associated with your Facebook history, but we will not process this information.
12. Information we might obtain from third parties
12.1. We might obtain some non-personally identifiable information from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of data.
12.2. We might insert advertising on our partner websites, social networks or Advertising networks who might categorize website visitors with similar characteristics or interests into non-personally identifiable data segments and offer these segments to their own clients, visitors and subscribers. For example, if a person expresses an interest in cryptocurrency or beauty products, they might see an advertising banner linking to similar service provider company web site.
12.3. We might obtain and record information that an ad was requested or shown, how many times, the target geography of the ad (which will not include an IP address or specific personally identifiable location and any user interactions with the ad or the page where the ad appears. This information is used for analysis, reporting and troubleshooting. We do not perform any visitors profiling activities.
13. Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data
13.1. We have partnered with a number of authorized service providers (data processors), whose services and solutions complement, facilitate and enhance our own under written confidentiality agreements that guarantees that the requirements of the GDPR will be met and the rights of data subjects are protected. Data processors only act on behalf of our documented instructions. They have direct responsibilities under the GDPR and may be subject to fines or other sanctions if they don’t comply.
13.2. These might include: Hosting providers, Information technology service providers, data and cyber security services, web analytics, e-mail distribution and monitoring services, marketing services, content delivery networks (CDNs), our legal and financial advisors, accountants, insurance brokers and companies, delivery services.
13.3. Such data processors may receive or otherwise have access to your identifiable or non-identifiable personal data, in its entirety or in part depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Under no circumstances may data processors will use the data for their own purposes. Your personal data might be maintained, stored and processed at a destination outside the European Economic Area under our written instructions and regardless of any lesser legal requirements which may apply in their jurisdiction in Russia
13.4. Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or jurisdictional responsibilities.
14. Data retention
Unless otherwise specified, we may retain your Personal Information for as long as needed to provide you with information on our services and events or discuss with you any fundraising, volunteering or otherwise activities. As the data subject you have rights related to processing of your personal data and the option of withdrawing your consent for processing it at any time. Please see paragraph “Rights of users”.
15. Disclosure of information to third parties
We do not share personal information about you with other people or non-affiliated organization’s without your consent except to provide products or services you've requested, when we have your permission, or under the following circumstances:
15.1. We provide the information to trusted partners who provide us services under confidentiality agreements, specified in Paragraph “Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data. These companies do not have any independent right to share this information.
15.2. We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
15.3. In the event we are merged with a third party entity or undergo another change of control, we reserve the right to transfer information, including any PII and non-PII, to a successor entity. In this event, we will notify you by electronic means and obtain your consent before information about you is transferred and becomes subject to a different privacy policy.
16. International transfers
We may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention and national security.
17. Contacts
If you have any questions about this Privacy Policy, You can contact us: