Last updated: 23/05/2018
1. Who we are
1.1 We are Pixonic Games Ltd located at 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus.
1.3 For the purposes of relevant data protection legislation, Pixonic Games Ltd, is the data controller of the information you provide in submitting your resume or employment application.
2.1 By making available the Services we, acting reasonably and in good faith, believe that you:
(a) provide true information about yourself to the extent necessary for use of the Services;
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.
3. Information we collect about you
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: Your 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 Games Ltd 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.
4. Data sharing
4.1 We may share your personal information with companies, organisations and individuals inside and outside of the Pixonic Games Ltd 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 Games Ltd if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
o meet any applicable law, regulation, legal process or enforceable governmental request;
o detect, prevent or otherwise address fraud, security or technical issues; or
o 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 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.
5. 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.
6. 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 Games Ltd, 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.
6.2 You may request to remove your data on our Services by contacting the Service support (see Section 10 for details).
7. 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.
(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.
7.2 If you would like to exercise these rights, please contact Support Service at email@example.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.
8. Security Measures
8.1 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.
9. Changes to this Policy
10. Contact Us
10.2 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.
10.3 The e-mail address of our DPO is firstname.lastname@example.org.
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