Privacy Policy

PRIVACY POLICY

Last updated: August 31, 2021

  1. Who we are

1.1          We are MY.GAMES HOLDINGS LTD (fka Pixonic Games Ltd) located at 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus ("Pixonic ").

1.2          This Privacy Policy sets out how we collect and use your personal information when you use our website pixonic.com, including contact form ("Services"), offered by Pixonic and the choices available to you in connection with our use of your personal information (the Privacy Policy).

This Privacy Policy should be read alongside, and in addition to, our Terms of Service (accessible online at https://legal.pixonic.com/pixonic/terms_en.html) (Terms) and our Cookie Policy (accessible online at https://legal.pixonic.com/pixonic/cookies_en.html).

In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

1.3.         For the purposes of relevant data protection legislation, Pixonic, is the data controller of the information you provide in submitting your resume or employment application.

  1. This Privacy Policy

2.1          By making available the Services we, acting reasonably and in good faith, believe that you:

(a) have all necessary rights to register on and use the Services; 

(b) provide true information about yourself  to the extent necessary for use of the Services;

(c) are aware of and accept this Privacy Policy.

2.2          We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

  1. Information we collect about you

3.1          In order to implement the agreement between you and us, and provide you with access to the use of the Services and with feedback to your e-mail, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2          We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.

  • Information collected: Data you provide for registering in the Services such as e-mail address

Purpose: We use this information in order to manage and administer the Services provided to you. We use this information in order to communicate with you.

Legal basis: Legitimate interests.

  • Information collected: Information that you submit to us via contact form when send us an email, including those which contain your employment application (certain information about you including your name, address, date of birth, education and qualifications, training, previous employment, references and other related details you provide or provided about you in the course of your employment application).

Purpose: We use the information we collect from you for the purposes of:

• Evaluating and progressing your employment application;

• Creating your employee personnel file, if hired;

• Maintaining our own internal records of employment applications; and

• Protecting the rights and interests of Pixonic and others.

Legal basis: Legitimate interests.

3.3          We process your data for the purposes identified above, as necessary, (1) for the legitimate interests of us and other third parties, including maintaining and administrating the Services; (2) to comply with our legal obligations; and (3) to perform our obligations under your employment contract, should your application be successful. We also process your data where you have otherwise provided consent.

3.4          Please pay your attention, we do not collect and process information that usual automatically collected through a User’s interaction with services through cookies and other technologies.

3.5          Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.

We will not delete personal information if it is relevant to an investigation or a dispute.

It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.6          We do not require you to submit any special categories of personal data, such as personal data relating to your health or religion, as part of your employment application. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to send this information to us.

3.7          If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

  1. Data sharing

4.1          We may share your personal information with companies, organisations and individuals inside and outside of the Pixonic where one of the following circumstances applies:

• to other companies in our group, for administrative and management, subject to us taking reasonable measures to ensure that your information is kept secure at all times;

• to trusted third parties businesses, or persons who perform services and process your personal information for us for the purposes listed above, based on our instructions, subject to us taking reasonable measures to ensure that your information is kept secure at all times; and

• to companies, organisations or individuals outside of the Pixonic if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:

  • meet any applicable law, regulation, legal process or enforceable governmental request;
  • detect, prevent or otherwise address fraud, security or technical issues; or
  • protect against harm to the rights, property or safety of the Mail.ru Group, our customers or the public, as required or permitted by law.

4.2          MY.GAMES HOLDINGS LTD (fka Pixonic Games Ltd), My.com B.V., other companies in the Mail.ru Group or our selected third party partners with our permission, using their own ad servers, can show advertisements to you.

  1. International Transfers

5.1          We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in USA, Japan, Russia.

5.2          The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

  1. Retention Periods

6.1          We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law. Where you are unsuccessful in your application, but potentially your application might be suitable for future vacancies within Pixonic, we will keep your information during three (3) years, otherwise will delete immediately. If you are successful, this will be for the duration of your employment with Mail.ru Group plus a period following your employment, as required or permitted by law.

6.2          You may request to remove your data on our Services by contacting the Service support (see Section 12 for details).

6.3          We may remove your account, or the information you post as provided by the Terms.

  1. Your Rights

7.1          You have the following rights, in certain circumstances, in relation to your personal information:

(a) Right to access your personal information.

(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.

(c) Right to restrict the use of your personal information.

(d) Right to request that your personal information is erased, if:

- it is no longer required in relation to the purposes for which it was gathered or processed in another way;

- you withdraw your consent concerning processing subject to consent;

- you are justifiably opposed to the processing;

- it has been subject to illicit processing; or

- it is imposed by law.

(e) Right to object to processing of your personal information.

(f) Right to data portability (in certain specific circumstances).

(g) Right not to be subject to an automated decision.

(h) Right to lodge a complaint with a supervisory authority.

(i)  For processing based upon your consent, the right withdraw that consent at any time.

(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.

7.2          If you would like to exercise these rights, please contact Service support at legal@pixonic.com or send your request to us, in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on www.bloctel.fr.

  1. Your California Privacy Rights

8.1          This notice to California residents is provided under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. This notice supplements our Privacy Policy by explaining your California privacy rights if you are a California resident, and provides certain mandated disclosures about our treatment of California residents’ information, both online and offline.

8.2          If you are a California resident you have the following rights in relation to your personal information:

(a)        Right to Access. If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.

(b)        Right to Delete. If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

(c)        Process to Make a CCPA Request. To make an access or deletion request, please send your enquiries to Service support at legal@pixonic.com or send your request to us in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus.

(d)        Before completing your request, we may need to verify your identity or the identity of your authorized representative. We will then take action to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.

(e)        Right to Opt Out of Sale of Personal Information. If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA). You can exercise this right by amending the settings in the Services. Our Privacy Policy describes the limited circumstances in which we may share your information with third parties. Our Privacy Policy also provides you with certain controls and choices regarding our collection, use, and sharing of your information.

(f)        Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA.

(g)        Shine the Light Act. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us and our affiliates to third parties for the third parties’ direct marketing purposes. We are dedicated to treating your personal information with care and respect. For inquiries regarding our disclosure policy, you may send your enquiries to Service support at legal@pixonic.com or send your request to us in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus.

(h)        Authorized Agents. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.

(i)        Privacy Rights for California Minors. If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to view, correct and request the removal of content or information you have posted to the Site, message boards, or forums. You may exercise this right you may send your enquiries to Service support at legal@pixonic.com or send your request to us in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus. Note that any information posted to the message boards or forums is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive information.

Residual copies of content and/or information that have been deleted may remain on our backup servers. We do not have to remove posted content or information if it has been rendered anonymous. We may retain your information to resolve disputes, enforce our user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted the content or information.

8.3          Mandatory Disclosures. In addition to the information provided elsewhere in our Privacy Policy, we make the following disclosures for purposes of compliance with the CCPA:

•           We collected the following categories of personal information in the last 12 months: Identifiers, contact Information, demographic information, payment information associated with you, commercial information (such as information about goods and services you have purchased), Internet or other electronic network activity information, including information obtained from third parties, general location data (country, city), electronic information, and inferences drawn from the above. For detailed information please refer to “INFORMATION WE COLLECT ABOUT YOU” Section of this Privacy Policy.

•           The sources of personal information that we collected are: our users, directly, third party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and trusted sources who update or supplement information we hold about you.

•           The business or commercial purposes of collecting personal information are described in the “INFORMATION WE COLLECT ABOUT YOU” Section of this Privacy.

•           We disclosed the following categories of personal information for a business purpose in the last 12 months: IP addresses, Identifiers, information about your web browsing and app usage, demographic information, payment information associated with you, commercial information, Internet or other electronic network activity information, including information obtained from authorisation services of third parties, general location data (country, city), electronic information, and inferences drawn from the above. We disclose these categories outside only as described in the “DATA SHARING” Section of this Privacy Policy.

•           Although we do not sell personal information for monetary consideration, some of our partners may collect and process information when you interact with our Services, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our advertising properties and ads in order to provide you with relevant ads across the Internet and for other analytics purposes, and such partners may “sell” that information to other businesses for advertising and other purposes under the definition of “sale” in the CCPA.

•           As the term is defined by the CCPA, we “sold” the following categories of personal information in the last 12 months: IP addresses, Identifiers/Contact Information, Internet or other electronic network activity information, including information about your web browsing and app usage, and inferences drawn from the above. We “sold” each category to social networks (for the authorization purposes), advertising networks, data analytics providers and our infrastructure service providers.

•           The business or commercial purposes of “selling” personal information is for third party companies to perform services on our behalf, like marketing, advertising, performance and audience measurement.

•           We do not “sell” personal information of known minors under 16 years of age.

8.4          Online Tracking/Do Not Track. We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites. California Business and Professions Code Section 22575(b) (as amended effective January 1, 2014) permits our users who are California residents to be informed as to how we respond to Web browser "Do Not Track" settings. As Do Not Track is a standard that is currently being developed, we do not take actions to respond to Do Not Track settings, and instead we adhere to the standards set out in this Privacy Policy.

  1. Security Measures

9.1          We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

  1. Changes to this Policy

10.1          From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

  1. Contact Us

11.1       If you have any questions, please send your inquiries to Service support at legal@pixonic.com or send your request to us, in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

11.2       All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

11.3       The e-mail address of our DPO is dpo@corp.my.com.

  1.     Privacy Notice for parents/legal guardians

12.1      We encourage parents to discuss with their children the importance of personal data protection.

12.2      We will not require a child to provide more information than is reasonably necessary in order to use the Services.

12.3      If children are under 13 years old and under applicable law a parental consent is required, use of the Services if forbidden.

12.4       At any time, parent/legal guardian, who have revealed that their children use the Services in violation of these Privacy Policy, can request that we cease collecting of personal data of their children in association with a particular account, by sending a corresponding request via dpo@corp.my.com.

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