CarX Technologies Privacy Policy

CarX Technologies,  “TERMS OF USE AND PRIVACY POLICY”

Version 16.10.2018

 

PREAMBLE. GENERAL PROVISIONS

Thank you for playing the games and game services developed and published by CarX Technologies (CarX Technologies LTD)  (the “Game” or “Games”)! In this Privacy Policy “You” and “Your” refer to you, the person visiting or playing our Games and using other related services of CarX Technologies Limited (hereinafter referred to as “Services”). “We”, “Us” and “Our” refer to the staff, sites, and other resources of CarX Technologies, including CarX Technologies Limited and all its affiliates provided in this Privacy Policy.

This Privacy Policy was established in order to comply with the provisions of the General Data Protection Regulation (GDPR), legislation of the EU Member States and protect personal data rights of our users.

By using any Our Services, You agree with all the provisions of this Privacy Policy.

For the purposes of complying with GDPR the following terms are subject to application:

“Cookies” means small text files, located in browser directories. They are used to help users navigate through Services efficiently and perform certain functions of the Services.

“GDPR” means General Data Protection Regulation 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.

The term “information” includes personal data of data subjects.

“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.

When We use the term “personal information” or “personal data” in this Policy, it can include an individual’s first and last name, address, telephone number, e-mail address, and a credit card or other account number. The terms “personal information” and “personal data” are synonyms.

“Processing of the personal data” or “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Controller” means CarX Technologies Limited, the legal person that determines the purposes and means of the processing of personal data.

“Processors” means legal or natural persons specified in this Privacy Policy which process Your personal data on behalf of CarX Technologies Limited.

The terms “CarX Technologies” or “CarX Technologies Limited” include CarX Technologies Limited and its affiliates.

We believe in protecting Your privacy. Please read the following Privacy Policy to understand how We use and protect the information that You provide to Us.

 

  1. Contacting CarX Technologies

The controller of Your personal data is CarX Technologies Limited. CarX Technologies Limited is a company incorporated in Russian Federation. If You want to know what information We hold about You or if You have any other queries in relation to this Privacy Policy, please contact Us in writing.  Our contact information is below:

Postal Address:

76/2, Gilyrovskogo str,

129111, Moscow, Russia

Email:

info@carx-tech.com

 

Our processors that take part in processing of Your personal data on behalf of CarX Technologies Limited are:

(1) Amazon AWS

(2) Selectel ltd.

These processors provide CarX Technologies Limited with the services of support systems for Our Services.

They process Your personal data in accordance with the terms of the written contracts conсluded between CarX Technologies Limited and the processors. These contracts provide that the processors shall process and use Your personal data only to the extent provided in the contract. The terms of the contracts do not violate the processors’ obligations provided in Art.28 GDPR and Your rights as a personal data subject.

 

  1. Information That We Collect From You

2.1. CarX Technologies processes Your personal data under the consent given by You. We ask You for providing Us with the consent before processing Your personal data. When You use Our Services, We will collect the following categories of personal information about You:

(1) User ID

(2) Player’s payment ID;

(3) Device Token;

(4) Platform;

(5) Device ID;

(6) Device Name;

(7) Device Type;

(8) OS (Android, iOS);

(9) Country (location data);

(10) Display Width;

(11) Display Height;

(12) Core Count;

 

These personal data are processed by Our internal monitoring system.

2.2. We may also collect information about You, from any e-mails or letters that You send to Us. We will only use any such information in accordance with the terms of this Privacy Policy.

2.3. Any materials or information that You post or upload to the Games or to Us may be visible to other users of the Games and will be stored on Our servers for the purposes of making the Games available. We advise You to be selective about what information You post. Please do not include the following information in any post: telephone numbers, addresses, surname, date of birth, or other information you might want to hold private.

2.4. We may receive information that You submit to any third party website You access from links contained within the Games, including without limitation any third party payment processor or e-commerce portal provided by an e-commerce operator that may from time to time be made available to You via the Games. We and the owner/ operator of that third party website will be the data controller in respect to any such information.  You should check the privacy policy of such third party website to find out how they will use Your data. We will only use the information we receive in accordance with this Privacy Policy.

2.7. When You download CarX Technologies mobile application by or through a Third Party Platform You allow us to access and/or collect certain information from your Third Party Platform profile/account (for example, Your name, surname, e-mail, etc.). You additionally allow us to access information contained in cookies placed on your device by the Third Party Platform as permitted by the terms of your agreement and privacy settings with the Third Party Platform. We may share this information with the Third Party Platform for their use as permitted by the terms of your agreement and privacy settings with the Third Party Platform.

We will share some of the information we collect from You with vendors and other service providers who work with us to support the internal operations of our website and/or mobile application in accordance with this Privacy Policy. For example, we use a third-party service for ad tracking and to help us prepare website and mobile application analytics.

Our third-party ad tracking and analytics company never sends emails, notifications, or other communications to Our end users. Your choice to opt out of ad tracking and analytics services does not limit Our ability to email You or collect other information from You for other vendors, subject to the terms of this Privacy Policy.

 

  1. Use Of Your Information

3.1. We may use Your information for the following purposes:

(a)to administer Your membership account and identify You as the user of the Game;

(b)to enable Us to provide You with access to the Games and Services and adjust You to the Game ID;

(c)to enable You to download information and materials from the Games and Services;

(d)to provide You with services You subscribed to;

(e)to display Your username and contact details (for example, your nickname) to other players;

(f)to enable other members of the Games to contact You;

(g)to provide customer service in relation to Your use of the Games;

(h)to administer, support, improve and develop the Games;

(i) to control the quality of the Games;

(j) to conduct the internal analytics (including without limitation for displaying advertisement and Our promotions).

3.2. We may also use Your information to contact You about the Games or to send You other content We think may be of interest to You. We will only do this if You have so consented or requested to receive such information when you downloaded the Games. If at any time You no longer wish to be contacted, please let Us know in writing and We will arrange this.

3.3. We deem confidential any information about You that has not been officially disclosed, published and/or revealed, is not publicly available or commonly known, as well as legally or illegally circulated by any third party, and that may represent economic, financial, commercial, legal or any other value by virtue of its being unknown to a third party. Your personal data may become available for third parties only in cases provided in this Privacy Policy.

We also guarantee that employees of CarX Technologies Limited and all its affiliates that deal with Your personal data are under confidentiality and non-disclosure of personal data agreements.

We gather information, obtained in the course of Your use of Our Services, only for the purposes, specified by the present Privacy Policy.

3.4. You can be a subject to a decision based solely on automated processing, including profiling. It means that you can receive some information or offers which are based only on automated processing of your personal information (for example, personalized advertisements). You have the right to refuse to be a subject to a decision based solely on automated processing, including profiling. In this regard, please, contact Us via e-mail, specified in this Privacy Policy.

 

  1. Rights Of Data Subjects

4.1. You as the data subject have the following rights relating to the processing of Your personal data:

(1) Right of access (right to obtain from CarX Technologies Limited as the controller confirmation as to whether Your personal data are being processed and other information concerning Your personal data, including information about the purposes of processing, the categories of processed personal data, the categories of recipients of Your personal data, the period of personal data storage, the existence of automated decision-making, including profiling, in respect of Your personal data);

(2) Right to lodge a complaint with a supervisory authority (a supervisory authority is a state authority in your country which supervises the compliance with GDPR by legal and natural persons that process personal data of data subjects);

(3) Right to rectification (right to the rectification of inaccurate personal data concerning You) in accordance with Section 10 Privacy Policy;

(4) Right to erasure (right to obtain the erasure of personal data concerning You) in accordance with Section 10 Privacy Policy;

4.2. You may use Your rights by reading this Privacy Policy or sending requests relating to the rights provided in paras. (3)-(10) to Our e-mail specified in Chapter 1 “Contacting CarX Technologies” of this Privacy Policy.

 

  1. Disclosure Of Your Information

5.1. We will not share, sell or distribute any of the information You provide to Us without Your consent.

5.2. You should always be careful when submitting information about Yourself within the Games and You should only submit information that You consent to make public.

 

  1. Children

6.1. We do not knowingly collect or solicit personal information from anyone under 3 years old or knowingly allow such persons to register.

 

  1. Cookies

The Game doesn`t use cookies to ensure proper.

 

  1. Third Party Sites and Contributors

8.1. The Games may contain links to websites and microsites that are operated by third parties. If you click such links, you can be transferred to the websites and microsites of third parties. We do not control those websites and microsites and as such this Privacy Policy does not apply to those websites and microsites. Please consult the terms and conditions and privacy policies of those third party websites and microsites to find out how they collect and use Your personal data and to establish whether and for what purpose they use cookies.

8.2. Advertisements contained on Our Games operate as links to that advertiser’s websites and as such any information they collect by virtue of Your clicking on that link will be collected and used in accordance with the privacy policy of that advertiser.

 

  1. Security And Data Retention of personal data

We employ reasonable security measures to protect Your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage.

 

  1. Data Access and Corrections

10.1. You are entitled to see the information We hold about You and You may ask Us to make any necessary changes or rectifications to ensure that it is accurate and kept up to date. If You wish to do this, please contact Us in writing using the information provided above.

10.2. You may also withdraw Your consent for Us to process Your data at any time by notifying Us in writing by contact e-mail, specified in this Privacy Policy (Chapter 1 “Contacting CarX Technologies” of this Privacy Policy). But if You withdraw Your consent to all or certain types of processing described above We may be unable to maintain Your membership of the Games and you may no longer be able to access the Games, if it will be technically or practically impossible.

10.3. If you are accessing Our Games via Facebook, you may update, amend or delete Your information on Facebook, that we may receive from Facebook, by amending Your Facebook account information in accordance with Facebook’s terms and conditions of use.

 

  1. Changes To Our Privacy Policy

We reserve the right to make changes to Our Privacy Policy from time to time. Any such changes to Our privacy policy will be posted here. We will notify You about the changes by displaying the link to the updated text of the Policy at the screen of the Game.