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IGVAULT LIMITED (Address:51 Fortescue Road, London, United Kingdom) and its affiliated companies (the 'Controller’
or ‘IGVault’ or ‘we’) respect your privacy rights and recognize the importance of protecting the Personal data (as
defined below) provided by you to us. The privacy of each and every customer (the ‘Customer’ or ‘you’) matters to us,
and we strive for transparency in all of our data privacy practices, especially when it comes to identifying the
information we collect, use, share, and disclose (hereinafter – the Personal data), as well as the ways we help keep
your personal data safe. In order to that the Company is obligated to use and process the Personal data of the
regarding the Company's use of the Personal data you provide to us, and the actions you can take to access this
information and request that the Company correct or delete it.
To provide the Customers with their products and services and administer their account in relation to such
products and services, in particular to process their transaction, subscriptions and registration for our products and
services – in accordance with your agreements with us.
To process the transaction, subscriptions and registration for products and services of third-parties.
To detect, investigate and prevent fraud, to maintain the security of our systems, to protect our property and
safety as well as property and safety of our employees.
To conduct research and statistical analysis in order to improve and develop our business, products and services.
To provide you marketing information about our Group products and services as well as relevant third-party
products and services:
-by using direct marketing;
-by adapting our websites, offers and advertising to your interests;
-by other means, such as advertising on websites;
From time to time we may also collect personal data from other sources that the data subject – for example when
we identify beneficial owners within AML process or if you provide us personal data of other persons. In many cases
providing information included in this policy to such persons proves impossible or would involve a disproportionate
effort. We appreciate if you may help us to be transparent to such persons on processing of their data. Such data are
not used for marketing purposes.
The Company commits to comply with the provisions of General Data Protection Regulation, and all of the other
Laws and/or legal acts that are applicable, as well as all of the European Union acts that are applicable in
accordance with the Personal data protection regulations that are applicable for the specific country in which the
services are provided.
As required by law, and to enforce customers, or the Company's legal rights, and to comply with local, state,
federal and international law, the Company may disclose data to law enforcement agencies.
practices described herein with respect to the Company's collection, use ,store, share and disclosure the Personal
informed about any changes to it.
Personal Data Collection and Use Personal data
'Personal data' means data that can identify you as a specific individual, such as your name, address, phone
number, e-mail address, or other contact information, whether at work or at home.
On all Company web sites that collect Personal data, we specifically describe what information is required in
order to provide you with the product, service, or feature you have requested.
We collect Personal data when you contact us, when you register with us, when you use our products and services,
when you submit an order with us, when you visit our web sites or the web sites of certain of the Company's partners,
and when you enter promotions and sweepstakes.
We may collect and process your Personal data due to the direct marketing. Direct marketing is the activity that
is intended to offer the goods or services to you by post, telephone or other direct way as well as to inquire the
opinion of the Customers about the offered goods and services. If you do not agree with the processing of your
Personal data for the direct marketing purposes, the Personal data for the direct marketing is not processed. You are
granted with the right to withdraw your consent given for the processing of the Personal data for the purposes of the
Providing Personal data by you is voluntary, but the lack of some of them may prevent you from registering on the
Platform, using certain services, receiving a newsletter, buying products etc.
Where you have given your consent and have not subsequently opted out, we may also collect information about what
is watched and bought by you, at what price, in what amount or whether did you add specific products to the cart but
did not buy them and use it to create a profile of your interests on the basis of content that we think was
interesting for you (for example because you added it to the cart) as well as content that other users similar to you
have found engaging. By using [this profile of your interests we can adapt our marketing materials by replacing the
default content with content more relevant to your interests (for example we can show you games or other products that
we think you might like instead of the default offers)
Pursuant to the GDPR, you have following rights in relation to the processing of your Personal data:
- Right to be informed, which is satisfied through this notice.
- Right to erasure. You have the right to have your data erased and no longer processed if the personal data are
no longer necessary in relation to the purposes for which they were collected or otherwise processed, if consent was
withdrawn or objection was filed and there are no other legal basis for processing. If we have disclosed the personal
data in question to third parties, we will inform them about the erasure of the personal data, unless it is impossible
or involves disproportionate effort to do so.
- Right to restriction on processing. If there are grounds for restriction on processing, for example if you
contest the accuracy of your personal data, it will be stored and processed otherwise only if you consent or to
exercise legal claims, or for the protection of rights of another natural or legal person. If we have disclosed the
personal data in question to third parties, we will inform them about the restriction on the processing of the
personal data, unless it is impossible or involves disproportionate effort to do so. We will inform you before the
restriction is lifted.
- Right to objection to processing. You have the right to object to processing based on legitimate interests
(including profiling) and direct marketing (including profiling). We will no longer process you data, unless we have
compelling legitimate grounds for processing or we need to process the data for the establishment, exercise or defense
of legal claims.
- Right to portability. You have the right to receive personal data that you provided to us in a structured,
commonly used and machine-readable format and to transmit those data to another data controller.You may contact us to
exercise your rights through “Contact Information” section below.
- Right to lodge a complaint with a supervisory authority. If you are unhappy about the way we process personal
data you may contact us and, if you are unsatisfied with our answer, file a complaint to data protection authority in
[Poland] or in your country,
- Right to verify whether we hold your personal data, to obtain a copy of the data, and to correct any data that
- Right to request us to inform you of the type of personal data held by us. All data access requests shall be
made using the form prescribed by the Privacy Commissioner for Personal Data (“Privacy Commissioner”) ,
-Right to requests for access and correction of personal data or for information regarding policies and practices
and the kinds of data held by us should be addressed in writing and sent by post to us (see the “Contact Us” section
When you register with us on this site, you first complete the on-line registration form, which requires you to
create a username and password. During registration, you are also required to provide Personal data, which may include
name, billing address, shipping address, telephone number, e-mail address. We use this personal data so that we may
contact you about the services and products on the site(s) in which you have expressed interest or requested and to
facilitate the completion of an order.
Promotions, Contests and Sweepstakes
From time-to-time, the Company may provide you the opportunity to participate in promotions, contests or
sweepstakes on its web site(s). Such promotions, contests and sweepstakes will also be governed by the rules and
regulations posted with such promotions, contests and sweepstakes. If you participate, you will be required to
register with the Company, which will require you to provide certain Personal data. Participation in these promotions,
contests and sweepstakes is completely voluntary and you therefore have a choice whether or not to register and
provide your Personal data. The requested data typically includes contact information, such as name, shipping address,
e-mail address, and telephone number. We will use this information to notify winners and award prizes. Additionally,
during your registration process you may opt-in to receiving additional related communications us. If you decide to
If you wish to subscribe to the Company's newsletter(s), we will use your name and e-mail address to send the
newsletters to you.
Other Information Collected
Some data may be collected automatically every time you visit the Company's web sites, such as cookies and
computer data. In addition, data may be collected other independent, third-party sources. We also collect information
about which pages you visit within this site. This site visitation data is identified only by a unique URL.
The Company uses both session ID cookies and persistent cookies as part of its interaction with your browser. A
cookie is an alphanumeric identifier (a file) that the Company's web sites transfer to your computer's hard drive
through a web browser to enable its systems to recognize your browser for record-keeping purposes. A session ID cookie
expires when you close your browser, while a persistent cookie remains on your hard drive for an extended period of
We use session ID cookies to make it easier for you to navigate the our web sites. We use persistent cookies to
identify and track which sections of its web site you most often visit. We also use persistent cookies in areas of its
web site you must register, and you are able to customize the information you see, so that you don't have to enter
your preferences more than once.
By configuring the options in your browser, you may control how cookies are processed by your system. However, if
reenter the information required to complete an order during new or interrupted browser sessions.
control over these cookies (see 'Third Party Advertising' and 'Third Party Cookies' below). Accordingly, this Privacy
As is true of most web sites, the Company gathers certain information automatically and stores it in log files.
This information includes internet protocol (IP) addresses, browser type, internet services provider (ISP),
referring/exit pages, operating system, date/time stamp, and clickstream data. The Company uses this information to
analyze trends, to screen for fraud, to administer the Company's sites, to track users' movements around the web sites
and to gather demographic information about the Company's user base as a whole.
Clear Gifs (Web Beacons/Web Bugs)
The Company employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that helps it better
manage content on its web sites by informing the Company what content is effective. Clear gifs are tiny graphics with
a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In
contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages
and are about the size of the period at the end of this sentence.
The Company uses clear gifs in its HTML-based e-mails to inform itself of which e-mails have been opened by you.
This allows the Company to gauge the effectiveness of certain communications and the effectiveness of the Company's
marketing campaigns. If you would like to opt-out of these e-mails, please see 'Choice and Opt-Out' section of this
Special Offers and Updates
The Company collects data about which sections of its web site you visit most often, so that it can send you our
newsletter and data about relevant offers, promotions, contests, and sweepstakes which may interest you.
Accordingly, the Company will occasionally send you information on products, services, special deals, promotions
The Company may, but is not obligated, to send you strictly service-related announcements or rare occasions when
it is necessary to do so. For example, if our service is temporarily suspended for maintenance, we might send you an
Generally, you may not opt-out of these communications since they are not promotional in nature. If you do not
wish to receive them, you may have the option to deactivate your account.
We also collect data for research purposes and to provide anonymous reporting for internal and external clients.
The Company uses the data collected for its own internal marketing and demographic studies to improve customer service
and product offerings.
We will communicate with you in response to your inquiries, to provide the products and services you request, and
to manage your account. We will communicate with you by e-mail, live chat or telephone, in accordance with your
The Company stores data that it collects through cookies, log files, and third party sources to create a profile
of your preferences, in order to improve the content of the Company's web site for you.
The Company discloses the data collected to external service providers necessary to facilitate the following
outsourced operations: address verification, fraud screening and order shipping.
We may transfer your personal data to the following categories of recipients:
-other users of our products and services where this is necessary to perform our agreements with you, for example
when you purchase a game from a seller on the IGVault or transfer funds to the another user;
-other members of the Group;
-agents, contractors, advisors or third parties who provide administrative, telecommunications, computer,
payment, debt collection, data processing, legal or other services to igvault.com;
-financial institutions, payment service providers (such as banks, payment institutions or electronic money
institutions) as well as card organizations (such as VISA or MasterCard) which in connection with our payment
-persons and institutions that are allowed to request your personal data under applicable laws and regulations
through a court order, subpoena or other legal process, such as supervisory bodies, regulators or law enforcement
-other parties as notified to you at the time of collection.
IGvault is an international company. If personal data is transferred from European Union outside European
Economic Area, we make sure that adequate level of personal data protection is assured, for example by signing
standard contractual clauses for transfer of data. .
Links to Other Web Sites
Users may find advertising or other content on our Site that link to the sites and services of our partners,
suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that
appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In
addition, these sites or services, including their content and links, may be constantly changing. These sites and
services may have their own privacy policies and customer service policies. Browsing and interaction on any other
website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Storage and Security of Personal data Storage
We will store your personal data for as long as we have lawful grounds to do so. Specific retention periods
depend on the purpose and legal base of processing, for example:
- personal data required to provide services, for the time of providing such services and after that, for the
time required by legal provisions (e.g. on accountancy) or to handle possible claims
- personal data that must have been collected for anti-money laundering legislation requirements, including for
identification, screening and reporting, as a rule for 5 years after the termination of our relationship, unless we
are required to retain this information for the purposes of court or administrative proceedings, or 8 years to handle
- personal data processed on the basis of your consent, as a rule until such consent is withdrawn
- personal data processed on the basis of a legitimate interest, as a rule until you file an effective objection.
The Company protects the privacy and integrity of the data it collects by employing appropriate administrative
protocols, technical safeguards, and physical security controls designed to limit access, detect and prevent the
unauthorized access, improper disclosure, alteration, or destruction of the data under its control. The Company
transmits the data used by its external service providers for the specific outsourced operations listed above across
public and private networks via recognized encryption technologies, such as by using Secure Sockets layer (SSL)
software, which encrypts the data you input.
Although the Company follows the procedures set forth above to protect the Personal data submitted to the
Company, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while the
Company strives to use commercially acceptable means to protect your Personal data, the Company cannot guarantee its
If you have any questions about the Company's security on the its web sites, please feel free to send us an
e-mail at email@example.com.
The Company has a ZERO TOLERANCE policy for Internet fraud or any attempt to access or acquire customer or other
information on its web sites via illegal or surreptitious means. The Company works with local, national, and
international fraud investigation agencies and employs a variety of electronic and other means to discourage, detect,
and intercept fraudulent activities. The Company aggressively prosecutes, to the fullest extent of the law, those
perpetrators apprehended conducting fraudulent activities on its web site.
Agencies with which the Company cooperates are: state and local police authorities, the United States Federal
Bureau of Investigation, US and International Customs Agencies, and Interpol.
The Company's sites are not intended for or directed to persons under the age of 13. The Company does not buy or
sell products or services or to children. Any person who provides their information to the Company through the
Company's web sites represents to the Company that they are 13 years of age or older.
Changes to this Statement
material changes to this statement by placing prominent notice on the its web site.
You may contact the Company by e-mail at: firstname.lastname@example.org.