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PRIVACY POLICY

EFFECTIVE 25 MAY 2018

Toolbox Solution Ltd. (the “Platform Operator”, “We”, “Our”, or “Us”), which is the owner and operator of the Website (the “Website Operator”) at (the “Website”) has developed a Privacy Policy guaranteeing the protection of the personal data of Users (the “User”, “You”, or “Your”). This document (Policy) describes how We collect, use, disclose, transfer, and safeguard Your information to our Website and our Applications, and the services offered on each (collectively, “Services”).

1. Acceptance of the Terms of the Policy

By using any of our Services or the Website or Applications, You are indicating Your agreement to the terms and conditions of this Privacy Policy. Your continued use of the Website,Applications or Services indicates Your agreement to the terms and conditions of this Privacy Policy and all amendments made thereto.

2. GDPR AND YOUR RIGHT TO ACCESS YOUR PERSONAL DATA, CORRECT YOUR PERSONAL DATA, AND TO BE FORGOTTEN.

2.1. If you are a citizen of any country in the EU, you have certain rights regarding your personal data that are governed by the General Data Protection Regulation (“GDPR”) adopted by the EU Parliament. If the GDPR applies to you, you have the right to access personal data that we process, request corrections to any of that data, as well as request to be forgotten. Even if the GDPR doesn’t apply to you, we are committed to providing you with the same rights you would have if it did. Please read Chapter 3 “Rights of the data subject” (here) to learn what your rights are.

2.2. To receive a copy of the personal data we process, request that corrections be made to your personal data, or to request to be forgotten, please send your request by mail or email to: support@coinsup.com

3. The Personal Information We Collect

3.1 In the sense of the General Data Protection Regulation (GDPR), Personal information is understood to mean data that can be used to identify or contact a given person. The term “Personal Information” may include, for example, your name, your address, your telephone number, your e-mail address, your age, your gender, your game preferences, your mobile phone’s device ID, an IP address, and the advertising ID of your phone. Anonymous information (in such a way that the individual is not or no longer identifiable), which we are not in a position to relate to you, does not qualify as “Personal Information”.

3.2 In the course of creating Your Account Record on the Website, We collect information from the Account Records of social networks that You have indicated is “Public Information”: that is, information that is accessible for viewing by an unlimited number of persons, even if that information is not accurate. We do not collect other information or information to which access is limited.

3.3 The following is information which may be collected by Us from the Account Records of social networks:

3.3.1. ID (the “User Identification Number” on a social network: VKontakte, Facebook, Odnoklassniki, and so on)

3.3.2. The User’s first and last names (if indicated)

3.3.3. The User’s profile photo (if provided)

3.3.4. The User’s gender (if indicated)

3.3.5. The User’s year of birth (if indicated)

3.3.6. The User’s date and month of birth (if indicated)

3.4. For information about how social networks may disclose your information, including any information you make public, please consult the social network’s Privacy Policy. We have no control over how social networks use or disclose the personal information you provide to it. We store the information that we receive from social networks along with other information that we collect from you or receive about you.

3.5. We do not collect or process any of sensitive data unless it is required to be law such as in the event of a court case. Under most circumstances, the types of data listed below will be never be processed:

3.5.1. Race or ethnic origin

3.5.2. Political opinions

3.5.3. Religious or philosophical beliefs

3.5.4. Trade union memberships

3.5.6. Genetic or biometric data

3.5.6. Health or mortality

3.5.7. Sex life or sexual orientation

4. CHILDREN

Our Services are not designed for persons under 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law). We do not knowingly collect information from persons under 18, including children under 13 in particular. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

5. How We Use Your Personal Information

The User’s personal information is used by Us for provision of our Services to you, communication with you about your use of our Services, giving a respond to your inquiries, to fulfill your orders, and for other customer service purposes. The User’s personal information is used by Us as well as part of authorization the User by assigning an identification number in the process of creating a User Account Record on the Website. The User Identification Number allows Us to identify You on the Website, and is used by Us for technical and statistical purposes (including, but not limited to, product updates, product patches and fixes and other similar communications), allowing Us to assure optimal operation of the Website. We target ads to users, visitors and others both on and off our services directly or through a variety of partners.

6. LEGAL BASIS FOR PROCESSING DATA

6.1. We collect, use and share data as described above.

6.2. We will only collect and process personal information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you - learn more in our EULA) and “legitimate interests”.

6.3. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer - support@coinsup.com.

7. HOW LONG WE STORE YOUR PERSONAL INFORMATION

7.1. We retain personal information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations (no longer than is necessary for the purposes for which your personal data is processed). In accordance with our record keeping obligations, we will retain basic account information and information about performed transactions for at least 10 years after an account is closed.

7.2. If you submit a request to be forgotten, we will anonymize your personal data unless we have a legal obligation to continue to store the personal data, or for the establishment, exercise or defense of a legal claim. For example, if you have redeemed a Reward within any of our Applications we may store your personal data for as long the statute of limitations for making a claim relating to that redemption. If you have indicated in any way that you believe you have a dispute with us, we may store your personal data at least until that dispute is resolved.

7.3. We may store anonymized data indefinitely. We maintain this type of data to compare performance of our Site, our Applications and our Services over past periods, to analyze current performance, to measure player activity over time, and for other business uses.

8. How We Share Your Information

We may share the information that we receive from you, including personally identifiable information, as follows:

8.1. Our Users. Your username and any information that you post, including, without limitation, reviews, comments, scores, participation in the game, and text will be available to, and searchable by, all other Our Users.

8.2. Our Partners or Payment Gateways. We may share certain information (ex. your email address, IP address, User’s ID, country code, game nickname) regarding your Rewards with our partners such as DENGI-ONLINE, Wargaming Group Limited, Gaijin Network Ltd. The partners will use this information solely for the purpose of determining your eligibility for the Reward. Any information that you submit to a third party will be governed by that third party’s website privacy policy and not this Policy. We do not share your personal information with our partners or other third parties for their direct marketing purposes.

8.3. Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.

9. Disclosure of Your Information

9.1. We may be required to disclose Your personal information in accordance with the law, a legal process, or court proceedings, and/or on the basis of public inquiries or inquiries by government agencies inside or outside the country in which You are located.

9.2. We may also disclose information about You if We determine that such disclosure is necessary or appropriate for the purposes of national security, law enforcement, or other instances of public importance.

9.3. We may also disclose information about You if We determine that such disclosure is necessary in order to execute Our regulations and conditions, or for the purposes of protecting Our activity and Our users. Additionally, in the event of the reorganization, merger, or sale of the company, We may transfer any or all of the personal information We have collected to the relevant third party.

9.4. We do not sell or in any way provide personal information on Our users to third parties. This does not include trusted third parties which are providing Us with services concerned with the operation of the Website or management of Our business, as well as any other services. Information about You may be processed by Us and other members of Our corporate group and Our partners. Such parties are required to rigorously monitor and accept the regulations of this Privacy Policy. Information about You may be processed both within and outside the jurisdictions of the British Virgin Islands and the EEC.

9.5. In addition to the disclosure of information in accordance with Clauses 8.1–8.4 of this Privacy Policy, We may also disclose information about You to Our employees and the employees of other companies in Our corporate group. All parties receiving information about You are required to comply with current data protection legislation and ensure the Privacy of Your information to the same extent to which We are bound by those obligations.

10. Collection of Non-Personal Information

10.1. We also collect information that is not personal: data that does not enable a direct association with any specific person. We may collect, use, transfer, and disclose non-personal information for any purposes. For example, We may collect information such as data on type of employment, language, zip code, area code, unique device identifier, and the location and time zone in which the Website is being used in order to better understand consumer behavior and improve Our products, services, and advertising. For the purposes of this Privacy Policy, the sum total of those data is regarded as non-personal information.

10.2. If We combine non-personal information with personal information, such combined information will be regarded as personal information for as long as that information is combined.

11. Information Requested during Withdrawal of Funds

Funds that are earned can be withdrawn using any of the methods listed on the Website. In order to withdraw funds, We request that You indicate and confirm Your cellphone number in Your Account Record.

12. Information Collected Automatically: Cookies

12.1. The Website may make use of cookies and other technology that allows personalization of the viewing of Our Website. A cookie is text information located in a temporary file that We send via the web server to the User’s computer in order to save the session in the browser, and to identify You the next time You visit the Website. Cookies do not contain personal User data. These files contain exclusively technical information that is non-specific and necessary for the identification of the User on the Website. Some of Our partners may also use cookies: for example, when placing advertisements. Please note that We do not have access to such cookies. Our partners’ cookies are regulated by their own Confidentiality Policies.

12.2. You are not required to accept cookies from Us, and You may accept or refuse them. If You want to turn off cookies in Your web browser, follow the instructions for Your browser:

12.3. Additional information on the placement, use, and deletion of cookies can be found at http://www.cookiecentral.com/faq and http://www.aboutcookies.org

13. Security of and Access to Your Information

13.1. We strive to maintain maximum accuracy of the information about You that We have at Our disposal. You can contact Our Support Service at any time at support@coinsup.com in order to review, change, or receive a copy of the information about You, or for the purpose of making necessary amendments to that information. The following options regards to your right in details are listed below:

13.1.1. Delete data: You can request deletion of your personal data that we have about you. We will delete the data that we are not legally obliged to keep and since some of the data is necessary to provide Our Services to you, you will not be able to use our services after the deletion;

13.1.2. Change or correct data: You have the right to request change of incorrect personal data that we have about you;

13.1.3. Object to or limit or restrict use of data: You can request that we stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

13.1.4. Right to access and/or take your personal data: You have the right to ask us for a copy of your personal data and can ask for a copy of personal data.

13.1.5. You also have the right to lodge a complaint at a supervisory authority.

13.3. In certain circumstances, We may charge a minimal fee to cover administrative expenses connected with any request made by You in that regard.

13.4. Users may independently make changes to Account Record data on the Website using the “My Profile” link on the menu

  • 13.4.1. Your email address

  • 13.4.2. Your cellphone number and other telephone number

  • 13.4.3. Your data, including the photo in Account Records on social networks

  • 13.4.4. Your country

Please read Chapter 3 “Rights of the data subject” (here) of the Regulation (EU) 2016/679 (General Data Protection Regulation) to learn more what your rights are.

13.5. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. To change your social net’s password, you must go to the social net’s site and follow its procedures for changing your password.

14. Deletion of an Account Record on the Website

14.1. Users may change or delete information about themselves in the User Account Record on the Website by sending a message to the Support Service at support@coinsup.com. Your account will be deleted and your personal data will be de-personalized within 30 days of receiving your request.

14.2. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse or enforce our EULA. We will retain de-personalized after your account has been deleted.

15. Protection of Personal Information

15.1. The Website Operator makes significant efforts, including taking every administrative, technical, and physical precautionary measure within its power, to protect Your personal information from loss, theft, and dishonest use, as well as from unauthorized access, disclosure, amendment, and deletion.

15.2. The personal information You post on social networks, on forums, or in chat rooms is visible to other users and may be read, collected, or used by them. You are responsible for the personal information that You prefer to provide in such cases.

16. Amendments to the Confidentiality Policy

16.1. We reserve the right to amend this Confidentiality Policy at any time. Amendments to the Confidentiality Policy shall come into force immediately after they are posted on the Website, and will be accessible on the Website’s home page or in the “News” section.

17. Applicable Law

When processing Your personal data, We rigorously comply with the regulations of English Common Law, including the Data Protection Act 1998.

18. About Us

Toolbox Solution Ltd.

Registration number: 1719057

Address: Geneva Place, Waterfront Drive, PO Box 3469, Road Town, Tortola, British Virgin Islands

Bank: Rietumu Banka

Bank address: 7 Vesetas St., Riga, LV-1013, Latvia

IBAN: LV83RTMB0000624806144

SWIFT code: RTMBLV2X

Most recent update to the Privacy Policy: May 25, 2018