PRIVACY POLICY
This version of the
Privacy Policy came into force on January 29, 2024
This Privacy Policy (hereinafter referred to as the “Policy”)
describes how Axlebolt LTD (hereinafter referred to as “Axlebolt”, “we”
and derivatives) and its subsidiaries and affiliated companies process personal
data as part of providing access to services on the site axlebolt.com (hereinafter referred to as the “Site”). By
using our Site and/or agreeing to the Policy by filling out the relevant forms
on the Site, you or your legal representative (hereinafter referred to as the “User”)
accept this Policy.
If you are an underage person, please ask your parents
(legal representative) to read this Policy. For an underage person, the Policy
is accepted by his legal representative. If you are an underage person and you
are unable to present this Policy to your legal representative, or if you or
your legal representative does not agree with the terms of this Policy, please stop
using the Site immediately.
If a legal representative allows an underage person to
use the Site, we presume that the legal representative has read and accepted
the Policy on behalf of the underage person.
At the same time, we do not purposefully collect
personal data from Users under 18 since the Site is intended for a general
audience and is targeted at a wide range of individuals with full legal
capacity.
The Policy on https://axlebolt.com/en/privacy-policy is the most current version. We may update this
Policy unilaterally over time, in order, inert alia, to comply with
recent changes in applicable legislation and law enforcement. All changes are
effective when posted on this page. Please review the latest version of this
Privacy Policy on the Site from time to time.
1. WHAT
DATA DO WE COLLECT AND PROCESS?
We process the following information related to Users:
- Contact and personal information (if a User submits
their CV for consideration for our openings);
- Cookies: Technical, sessional and analytical.
We try to minimize the collection of personal data and
do not collect additional information about you.
In order to process User’s data, we obtain consent in
accordance with the Policy. Users have the option to withdraw their consent at
any time or to request the deletion of any information we have collected, but
in this case, we will be forced to restrict access to certain features of the
Site, including access to the Personal Account.
In addition to User’s consent, we rely on our
legitimate interest as the legal basis for data processing.
2. ON
WHAT BASIS AND WHAT FOR DO WE PROCESS THIS DATA?
Below you can find the legal basis and purpose for
collecting the personal data listed in Section 1 of this Policy:
|
Category of data |
Legal basis |
Characteristics of data
and purpose(s) of processing |
|
Contact information |
Your consent (including those which
expressed in conclusory acts) |
You can provide us with your
contact information by filling out a request form on the Site to receive
feedback and/or updates from us. We may use your email address (or whichever
communication method you have chosen as your primary means of contact) to contact
you regarding various matters. In addition, you may provide us with your
other contact information of your choice, as described below. |
|
Personal information |
Your consent (including those which
expressed in conclusory acts) |
This type of data may contain
personal information that identifies you personally. Using the Site, you can
send us (by attaching or sending your CV through the Site or by email) your CV
for employment, which may contain the following information: Your first name,
surname, gender, age, ethnicity, photo image, place of residence, hobbies,
links to social media accounts, education, work experience, phone number, zip
code, mailing address, other contact information, and other personal
information you may put on your resume. When you send us your CV, it is up to
you to determine the specific amount of your personal information that we
collect and process. |
|
Analytical, sessional
and technical Cookies |
·
Consent
(including expressed in conclusory acts) ·
Our
legitimate interest in obtaining static data for market analysis and research
and improvement the quality of services and the Site |
Cookies are small text files that
are stored on your device during your visit a website. We use cookies to
anonymously analyze use of the Site, as well as to provide you with
additional features on the website, facilitate your interaction with the Site
and ensure error-free use (for example, to make it easier to navigate the Site
or to save your preferences and settings for your next visit). |
3. FOR
WHAT PURPOSES DO WE PROCESS PERSONAL DATA?
We process your data in order to provide information
services related to the Site and its functions, as well as to review CV you
have provided. At the same time, we use your data to contact you as necessary.
We DO NOT process your personal data to sell it.
We also process your personal data where we have a
duty to do so under applicable law.
4. TO
WHOM PERSONAL DATA MAY BE TRANSFERRED
By agreeing to this Policy, you comfirm that you
consent to the transfer of your data pointed in this Policy to our affiliates
and partners that are not affiliated with us.
We do guarantee that agreements entered into with
third parties provide a level of protection no lower than that provided for in
this Policy, which complies with the requirements of Russian legislation on
personal data.
Transfer for commercial purposes
In order to provide you with the best possible user
experience and to comply with the terms of the User Agreement between you and
us, we may share your personal data with third parties.
We transfer data to third parties for only the
following purposes:
1) Improving the quality of the Site and services
provided, market research
We allow third-party services to collect your data so
that we can provide services to our Users, measure, analyze and improve Site
performance, and continuously update and improve our Site and services.
We may use this information to correct any errors on
the Site, evaluate our User demographics data and determine whether new device
types need to be supported for the Site, and determine whether changes to our
marketing and distribution solutions are necessary.
Cookies may be provided and used by us to learn more
about our audience and the effectiveness of the measures we use to attract
interest in our Site and the services on it, the viability of the services as
business projects.
In this regard, the following categories of personal
data may be shared with partners:
- Analytical, sessional and technical Cookies.
The listed data are transferred to the following third
parties:
|
YANDEX, LLC (TIN 7736207543, PSRN
1027700229193). Here you can read the privacy policy of Yandex LLC |
|
Google, Inc. (1600 Amphitheatre Parkway, Mountain View, California, 94043, США. Here you can read the privacy policy of Google LLC |
The information collected by Cookie cannot identify
you, but it can help us improve our Site.
2) Transfer by virtue of law
We may disclose information that you provide in order
to respond to subpoenas, requests, notices, court orders, requests from public
authorities in any proceeding, and to establish / exercise our rights.
We may also disclose your information to protect from
legal claims if we believe that disclosure is necessary to protect our rights,
your safety or the safety of others, to investigate fraud, or to respond to a
government request.
We may transfer your information in order to
investigate, prevent or take action regarding illegal activities, suspected
fraud and situations involving potential threats to the physical safety of any
person, or as otherwise required by law.
5. CAN WE
RECEIVE PERSONAL DATA FROM THIRD PARTIES?
At the present time the functionality and mechanisms
of the Site do not involve the receipt of personal data from third parties.
6. HOW
LONG DO WE KEEP YOUR PERSONAL DATA?
We will process your personal data for as long as you
continue to use the Site. If you stop using the Site, as a general rule, we
will continue to process your personal data for the next 2 years so that you can
resume using the Site and we can use the data for analytical purposes. After
that period, we will delete your personal data. We may also delete your
personal data earlier than the determined period in case we no longer need it.
Please note that a different processing period may be
stipulated for Cookies.
7. IS
USER DATA IN SECURE?
The security of your personal data is important to us.
We follow generally accepted standards to protect your
information both during transferring and after it is received. However, no
method of transfer over the Internet or method of electronic storage is 100%
secure. Therefore, we cannot guarantee absolute security.
While no security system is completely secure, we and
our partners take appropriate security measures to protect against unauthorized
access or disclosure of the information we collect. For Axlebolt, this
includes, among other things:
·
preventing
disclosure of your data unless necessary
·
ensuring
that all information collected by Axlebolt is transferred over secure
connections,
·
protection
and encryption by software with the appropriate level to protect against
unauthorized access.
Our employees and third parties who access your data
are obliged to keep your data confidential.
8. WHAT
RIGHTS DO I HAVE?
For users in the European Union
If you are a resident of the European Union, you have
rights under applicable data protection laws. These include:
• The right of access. You have the right to request
and receive a copy of your data available to us;
• The right to correction or deletion. You have the
right to request the correction or deletion of your data available to us;
• The right to restrict processing. You have the right
to restrict the processing of your data at our disposal;
• The right to data portability. You have the right to
transfer your data at our disposal (transfer the data to another controller).
At the same time, we are not responsible for the compatibility of data with a
third-party service.
In certain circumstances, you may also have the right
to object to the processing of your data. To send such a request, please use
the contact information provided in the "Contact us" section. We will
review any such request and take action in accordance with applicable data
protection laws.
If we rely on your consent to the processing of your
personal data, you have the right to withdraw your consent at any time.
However, this will not affect the legality of processing until such consent is
revoked. Please also note that in addition to your consent, we may have other
legitimate grounds for processing certain categories of data, so if you
disagree with their processing, you must delete your account in the Game.
Transfer of personal data outside the EU. Since some
of our Analytics Services, Advertising Partners, and Third-party resources for
fighting are located in countries outside the European Union, your personal
data may be transferred to countries that may not provide the same level of
data privacy as the laws of your country of residence. When transferring data
across borders, we rely solely on the legitimate grounds for such transfer.
Although we and our partners take all reasonable and
necessary measures to protect your personal data from unauthorized access by
third parties, we are obliged to inform you about the possible risks of such
storage of your personal data in jurisdictions outside the European Union in
accordance with Article 49(1)(a) GDPR.
By agreeing to the processing of your personal data in
accordance with this Privacy Policy, you give us your express consent to the
cross-border transfer of your personal data.
For residents of the Russian Federation
If you are a personal data subject from the Russian
Federation, then you have the right to ensure the protection of your rights and
freedoms when processing personal Data, protection of the rights to privacy,
personal and family secrets, in particular you have the right:
• require us, as an operator, to clarify your Personal
data, block or destroy it if the personal data is incomplete, outdated,
inaccurate, illegally obtained or is not necessary for the stated purpose of
processing, as well as take legal measures to protect your rights;
• to receive information related to the processing of
your Personal Data, including: confirmation of the fact of processing Personal
Data by the operator; legal grounds and purposes of processing Personal Data;
purposes and methods of processing Personal Data used by the operator; name and
location of the operator, information about persons (except for employees of
the operator) who have access to Personal Data or to whom Personal Data may be
disclosed on the basis of an agreement with the operator or on the basis of
Federal Law; processed Personal Data related to the relevant Personal Data
subject, the source of their receipt; terms of processing of Personal Data,
including the terms of their storage; information about the performed or
proposed cross-border data transfer; name or surname, first name, patronymic
and address of the person processing Personal Data on behalf of the operator,
if processing is entrusted or will be assigned to such a person; other
information;
• to protect their rights and legitimate interests,
including compensation for damages and (or) compensation for moral damage in
court.
For residents of Brazil
If Brazilian law applies to the processing of your
Personal Data, you have the right to request from Axlebolt:
• confirmation of the fact of data processing;
• access to processed data;
• correction of incomplete, inaccurate or outdated
data;
• Anonymization, blocking or deletion of unnecessary,
redundant data or data processed in violation of the provisions of the
Brazilian Data Protection Act (LGPD);
• the possibility of transferring data to another
service or product provider through a direct request in accordance with the
requirements of the National Data protection Authority (ANPD) and taking into
account the requirements of commercial and industrial secrets;
• deletion of personal data processed with your
consent;
• information about public and private organizations
with which Axlebolt has shared data;
• information about the possibility of refusal of
consent and the consequences of such refusal.
You can also withdraw your consent to the processing
of Personal Data, object to the processing carried out on the basis of one of
the situations of refusal of consent, if there is a violation of the provisions
of the LGPD. We do not make decisions based solely on automated processing of
Personal Data, however, in any case you have the right to review decisions made
solely on the basis of automated processing of personal data affecting your
interests, including decisions aimed at determining your personal, professional,
consumer and credit profile or other aspects of your personality.
For data subjects located in the Republic of Turkey
The Personal Data Protection Act No. 6698 (“DPL”)
contains the rights of data subjects accessing services from the Republic of
Turkey. You have the right to contact the data controller in order to:
• find out if your personal data is being processed;
• request information about whether your personal data
has been processed;
• find out the purpose of processing your personal
data and whether this personal data is used in accordance with the purpose;
• know the third parties to whom your personal data is
transferred in the country or abroad;
• request correction of incomplete or inaccurate data,
if any;
• request the deletion of your personal data in
accordance with the conditions specified in Article 7 of the DPL;
• request reporting on transactions carried out in
certain cases from third parties to whom your personal data has been
transferred;
• independently object to the occurrence of a result
in relation to this person by analyzing data processed exclusively using
automated systems;
• claim compensation for damages resulting from the
illegal processing of your personal data.
For residents of California
The California Consumer Privacy Protection Act
("CCPA") grants California residents the following rights:
The right to access/inform. You have the right to
request that we provide you with the following information:
•
categories
and specific elements of Personal Data that we have collected about you over
the past 12 months;
•
categories
of sources from which we collect Personal Data;
•
business
or commercial purposes for the collection, use, exchange or sale of Personal
Data;
•
the
categories of Personal Data that we have disclosed about you for commercial
purposes and the categories of recipients to whom they have been disclosed;
•
categories
of Personal Data that we have sold or transferred, and categories of third
parties to whom each type of Personal Data has been sold or transferred.
•
The
right to delete. You have the right to request that we delete Personal Data
under certain circumstances, with some exceptions.
•
The
right to correction. You have the right to request that we correct the Personal
Data that we store about you if you believe that it is inaccurate. We may
request the relevant documents from you in connection with your request. After
receiving and validating a request to correct inaccurate Personal Data, we will
make all commercially reasonable efforts to correct the Personal Data.
•
The
right of refusal. We do not sell your Personal Data. However, in any case, you
have the right to refuse the sale and exchange of your Personal Data.
•
If you
wish to opt out of the sale and sharing, except through Cookies or other online
tracking technologies, you can contact us using the methods listed below in the
"Contact Us" section.
•
The
right to non-discrimination. You have the right not to be discriminated against
for exercising the rights set out in the CCPA.
Contact the data protection authorities
For residents of the European Union: If you live in
the European Union and believe that we are illegally processing your personal
data, you have the right to file a complaint with the local data protection
supervisory authority. You can find contact information here: https://commission.europa.eu/about-european-commission/contact_en.
For residents of the Russian Federation: if you
believe that your rights are being violated, you can contact the Authorized
Body for the Protection of the rights of personal data subjects – Federal
Service for Supervision of Communications. You can find contact information at:
https://rkn.gov.ru/contacts /.
For residents of Brazil: if you believe that our
interaction with your personal data violates applicable law, you can send a
corresponding request to the Brazilian Data Protection Authority (ANPD).
For California residents: If you are a CCPA subject,
you have the right to file a complaint with the California Data Protection
Agency at the following email address: [email protected].
For residents of the Republic of Turkey: if you
believe that your rights are being violated, you can contact the Office for
Personal Data Protection. You can find contact information here: https://www.kvkk.gov.tr/Icerik/6655/Contact-Us.
Contact us
If you want to exercise the above rights or contact us
for another reason, please contact us at [email protected].
You can also write to us at: Christodoulou
Chatzipavlou, 221, Helios Court, Flat 401, 3036, Limassol, Cyprus.
Please note that in order to fulfill the request, we
may need additional information to identify the person who contacted us. If the
provision of information may lead to a violation of the rights and legitimate
interests of third parties, we may refuse to provide information.
To exercise the rights mentioned above, your request
must contain the following information:
• your email address;
• information confirming that you are connected to us,
or information otherwise confirming that we process your personal data.
9. WHERE
IS MY PERSONAL DATA BEING STORED?
We
store data in Germany (Frankfurt), which provides an adequate level of data
protection.
The
data is stored by AMAZON WEB SERVICES EMEA SARL (CC OTH 00760863 2022 TR). You
can read the privacy policy of AMAZON WEB SERVICES.
By
agreeing to the Policy, you consent to the transfer of Personal Data to the
territory of Germany.
Thank
you for choosing our services!
Sincerely yours,
Axlebolt team