Personal Data Processing Policy

1. General provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by GAMES ASSET (hereinafter - the Operator).


1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator Personal Data Processing Policy (the "Policy") applies to all information that Operator may obtain about visitors to the website https://activo.games.


2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer equipment.

2.2. Blocking of personal data - temporary termination of the processing of personal data (except if processing is necessary to clarify personal data).

2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://activo.games.

2.4. Personal data information system - a set of personal data contained in databases and providing their processing by information technologies and technical means.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other personal data subject.

2.6. Personal data processing - any action (operation) or a set of actions (operations) performed using automation means or without using such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal entity or individual, independently or together with other persons, organizing and/or processing personal data, as well as determining the purpose of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal Data means any information relating directly or indirectly to a particular or defined Website User https://activo.games.2.6. Personal data processing - any action (operation) or a set of actions (operations) performed using automation means or without using such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.9. Personal data allowed by the personal data subject for distribution - personal data, access of an unlimited number of persons to which is provided by the personal data subject by giving consent to the processing of personal data allowed by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data allowed for distribution).

2.10. User - any visitor to the website https://activo.games.

2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or to familiarize with personal data of an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data are permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.


3. Basic rights and obligations of the Operator

3.1. The operator has the right to:

- receive reliable information and/or documents containing personal data from the personal data subject;

- if the personal data subject withdraws his/her consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;

- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator shall:

- provide the personal data subject, at his request, with information concerning the processing of his personal data;

- organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;

- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

- inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receipt of such a request;

- publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

- take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;

- perform other duties stipulated by the Law on Personal Data.


4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

- receive information related to the processing of his personal data, except for cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data related to other personal data subjects, unless there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for its receipt are established by the Law on Personal Data;

- require the operator to clarify his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;

- put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;

- withdrawal of consent to the processing of personal data, as well as sending a request to terminate the processing of personal data;

- appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator when processing his personal data;

- to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

- provide the Operator with reliable data about itself;

- inform the Operator about clarification (update, change) of their personal data.

4.3. Persons who provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.


5. Principles of personal data processing

5.1. Processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. Processing of personal data incompatible with the purpose of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data that meet the goals of their processing are subject to processing.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator shall take the necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.5.4. Only personal data that meet the goals of their processing are subject to processing.

5.7. Personal data shall be stored in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or surety. Personal data processed shall be destroyed or depersonalized upon achievement of processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.


6. Purposes of personal data processing

7. Conditions of personal data processing

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals stipulated by the international agreement of the Russian Federation or the law, to carry out the functions, powers and obligations assigned by the legislation of the Russian Federation to the operator.

7.3. Processing of personal data is necessary for the implementation of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data are processed, access of an unlimited number of persons to which is granted by the personal data subject or at his request (hereinafter referred to as publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.



8. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of identification of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's e-mail address info@activo.games marked "Updating personal data."

8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is provided for by the contract or applicable law.

The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator's e-mail address info@activo.games marked "Withdrawal of consent to the processing of personal data."

8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. Personal data subject and/or with the specified documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions for processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator shall ensure confidentiality of personal data.

8.8. The Operator shall store personal data in a form that allows identifying the personal data subject for no longer than the purpose of personal data processing requires, unless the period of storage of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or surety.

8.9. A condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement to terminate the processing of personal data, as well as the identification of illegal processing of personal data.


9. List of actions performed by the Operator with the received personal data

9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (distribute, provide, access), depersonalize, block, delete and destroy personal data.

9.2. Operator performs automated processing of personal data with receipt and/or transmission of received information via information and telecommunication networks or without it.


10. Cross-border transfer of personal data

10.1. The operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification shall be sent separately from the notice of intention to process personal data) prior to the start of the cross-border transfer of personal data.

10.2. Before submitting the above notification, the operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to which cross-border transfer of personal data is planned.


11. Privacy of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.


12. Final provisions

12.1. The User may receive any clarifications on issues of interest related to the processing of his personal data by contacting the Operator via e-mail info@activo.games.

12.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced with a new version.

12.3. The current version of the Policy is freely available on the Internet at https://activo.games.