Last updated: April 26th, 2024
1. The policy
1.1. This privacy policy (the “Privacy Policy”) regulates the processing of personal data on the platform created and run by in4play OÜ, registry code 14946494 (“in4play”). The platform is available on the website of in4play at https://in4play.com/ (the “Platform”).
1.2. When signing up for an account on the Platform, you will be asked to confirm that you have read and agree with the terms stipulated in this Privacy Policy.
1.3. Please read the following terms carefully before you start using the services of in4play. If you do not agree with the terms stipulated in this Privacy Policy, please do not use the Platform.
1.4. in4play is committed to protecting the Client’s personal data. When processing personal data, in4play follows the rules stipulated in applicable data protection related legal acts, most importantly Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter the “GDPR”).
2. The controller
2.1. The data controller is in4play OÜ (registry code: 14946494). You can contact in4play via email at [email protected] or by sending a regular post to Tööstuse tn 85-38, 10416 Tallinn, Estonia.
3. The data purposes and legal grounds
3.1. in4play processes your personal data for the following purposes:
3.1.1. to provide you with the services offered by in4play. The legal basis for the processing of personal data is Article 6(1)(b) in the GDPR;
3.1.2. to make more of such services available to you where possible and appropriate. The legal basis for the processing of personal data is either Article 6(1)(b) or Article 6(1)(f) in the GDPR – the legitimate interest of in4play to offer additional services to the Client when appropriate;
3.1.3. for the purposes of security and control related to the service. The legal basis for the processing of personal data is Article 6(1)(f) in the GDPR – the legitimate interest of in4play to fulfill the information security requirements;
3.1.4. to satisfy regulatory and legal requirements. The legal basis for the processing of personal data is Article(1)(c);
3.1.5. to communicate offers, newsletters or other types of marketing material to you. The legal basis for this is either your consent (Article 6(1)(a) in the GDPR) or, in cases where you have subscribed to one of our channels on a social media platform, the legal basis is Article 6(1)(b).
3.2. in4play collects the following personal data:
3.2.1. your full name;
3.2.2. date of birth;
3.2.3. contact information (address, email address, phone number);
3.2.4. IP address;
3.2.5. If the Client uses an e-wallet, in4play will collect information about the full name and the email of the Client;
3.2.6. when the Client makes payments, in4play collects information about the billing details regarding the payment (full name, billing address, phone number, email address);
3.2.7. log information regarding your account’s confirmation, account creation date, and account deletion date.
3.3. in4play collects some metadata such as browser information in server logs in case of an issue or an attack on the service. For that reason, the IP address is also processed.
3.4. Please note that if the Client refuses to provide certain personal data to in4play, it may happen that the Client will not be able to use the service.
4. Time of storage
4.1. in4play stores the personal data of you only as long as it is necessary, in accordance with the aim of collecting the data. Please note that in4play stores billing information (including address and IP address) as long as required by law.
4.2. in4play will store your personal data accordingly:
4.2.1. Personal data which the Client has provided for account creation will be stored until the Client deletes its account.
4.2.2. Personal data for affiliation purposes will be stored until the Client is in4play’s affiliate.
4.2.3. Personal data which the Client has provided on social media: in4play will have access to this personal data during the time when the Client is a follower of in4play on the social media platform.
4.2.4. Personal data related to billing [A15] will be stored for seven years as of the end of the financial year when the transaction was recorded, according to accounting laws.
4.3. Metadata such as IP addresses and browser information will be removed 90 days after the collection.
5. Recipients and data processors
5.1. in4play does not disclose personal data to third parties without your consent, except to the supervisory authorities, accountants, and in events arising from law or in case needed for submission or in the processing of a claim against you.
5.2. in4play may use the services of other persons when this is necessary to maintain the Platform and/or provide the services of the Platform. In this case, in4play is engaging other parties as data processors (including the webmaster, accountant, social media manager). When in4play makes use of data processors, in4play shall comply with all the requirements stipulated in Article 28 of the GDPR. in4play will sign a data processing agreement with the data processors according to Article 28(3) in the GDPR.
6. Security measures
6.1. in4play has had a security audit from security experts to ensure that the data is as safe as possible.
6.2. in4play keeps your data safe by using organizational, physical, and technological measures.
6.3. The access to personal data is restricted and certain access rights are set.
7. Data location and transfer to third countries or international organizations
7.1. The data processing (including storing) takes place in in4play’s servers in Gravelines, France.
7.2. in4play does not transfer the data to third countries.
8. Data subject’s rights
8.1. As a data subject, the Client has the following rights, subject to the conditions stipulated in applicable legal acts:
8.1.1. right to correct any inaccurate personal data;
8.1.2. right to access the personal data;
8.1.3. right to submit a claim with a relevant data protection supervisory authority or a court when the Client believes that its rights regarding personal data have been violated;
8.1.4. right to restrict the processing of personal data;
8.1.5. right to ask personal data to be erased;
8.1.6. right to data portability;
8.1.7. right to withdraw consent at any time (where personal data is being processed based on consent) without this affecting the lawfulness of processing based on consent before its withdrawal.
8.2. If the Client wishes to exercise any of its rights as a data subject, then the Client should submit a request to in4play, using the contact details given in clause 2.1.
9. Cookies
9.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
9.2. in4play uses session cookies on the Platform. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
9.3. Like most online services and mobile applications, in4play or in4play’s authorized service providers may use cookies and other similar technologies for storing information to help provide you with a better, faster, and safer experience, and for advertising purposes.
9.4. in4play uses the following cookies:
9.4.1. A cookie used to keep you logged in and verify requests on the server (persistent);
9.4.2. Google analytics cookies: Two cookies which register a unique ID that is used to generate statistical data on how you use the website (one is valid for session only, the other is persistent). You can find more information about what Google Analytics collects and their privacy policies on the Google Analytics website https://www.google.com/intl/en/policies/privacy/. You can choose not to submit certain information by opting-out, please see here for details https://tools.google.com/dlpage/gaoptout.
9.4.3. Facebook pixel cookies: in4play uses both the first-party cookie data and third-party cookie data with the Facebook pixel. You can read more information about what Facebook pixel collects and their privacy policy at: https://www.facebook.com/business/help/471978536642445?id=1205376682832142. You can view your Facebook ads settings and update them at any time at: https://www.facebook.com/help/568137493302217.
9.4.4. Re-targeting cookies.
9.5. In addition to Google Analytics and Facebook pixel, in4play may also use other third-party service providers to help analyze how Clients use the in4play’s Platform. in4play’s advertisers and payment service providers may also send you cookies.
9.6. It is possible to reject cookies from your browsers (different browsers have different options). Blocking all cookies may affect the usage of in4play’s Platform.
10. Social media
10.1. in4play is present on the social media platforms of Facebook and Instagram. In addition, in4play uses WhatsApp, Twitch.tv, and Telegram channels to communicate with its customers and potential customers. in4play communicates with you via WhatsApp, Telegram, and Twitch only when you have subscribed to in4play’s channel on those sites. When communicating with you on social media, in4play abides by the applicable laws on data protection. The personal data which you provide to in4play upon subscribing will be used by in4play only. in4play will not share the personal data with any third parties.
10.2. When in4play is using WhatsApp, Twitch, and Telegram to communicate with its subscribers, it is acting as a data controller. The social media platform is acting as a data processor, providing a platform for in4play to carry out its marketing activities towards its subscribers. However, please note that the social media platform may also process your personal data for its own purposes. To find more information about how a social media platform is processing your personal data, please read carefully the privacy terms on the platform’s website.
10.3. Please note that when in4play is processing your personal data on its Facebook page, in4play is acting as a joint data controller with Facebook Ireland. More information about the personal data processing on Facebook can be found here: https://www.facebook.com/legal/controller_addendum.
11. Amendments
11.1. Please be aware that in4play may revise this Privacy Policy from time to time. Therefore, in4play’s Privacy Policy may be changed or amended. Any changes or amendments will be published on the Platform and sent to your registered email to notify you about the updates of the Privacy Policy. A notice about changes will be posted on the Platform’s homepage for a reasonable period of time prior to such changes come into force.
11.2. The effective date which is at the top of the Privacy Policy informs you about the latest version of the Privacy Policy. in4play advises you to revisit this page from time to time to make sure you are familiar with the current version of the Privacy Policy.
11.3. By continuing to access and use the Platform or the Services after in4play has posted changes on the Platform, or after notifying you by email, you agree to be bound by the updated Privacy Policy.
11.4. If you do not agree to the updated Privacy Policy, you must stop using the Platform or the Services.
12. Governing law, jurisdiction, and submitting complaints
12.1. This Privacy Policy and obligations arising from or related to it are governed by the legislation of the Republic of Estonia.
12.2. Any and all disputes arising from or related to the personal data protection will be settled by the parties by way of negotiations. Failing agreement, the parties have the right to lodge a claim to court.
12.3. In case the dispute between the parties is to be resolved in judicial proceedings, the parties agree to refer the dispute to Harju County Court in accordance with the legislation in force in the Republic of Estonia.
12.4. The above clauses shall not affect the rights of consumers regarding jurisdiction.
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