Privacy Policy

This version of the Privacy Policy is valid from September 20, 2024.

The purpose of this Policy is to provide you with information about how Axlebolt Limited processes your personal data (the "Policy"). This Policy explains how and why we use your information when you use our website: creators.standoff2.com (the "Website"). By agreeing to the Policy, and by filling out the relevant forms on the Website you (your legal representative) (the "User") accept the Policy.

Who We Are 

We, Axlebolt Limited (AXLEBOLT LTD), represent the controller of your personal data, i.e. we independently determine the purposes and means of processing your personal data. Axlebolt Limited (AXLEBOLT LTD) was established and operates in accordance with the laws of the Republic of Cyprus, registration number HE 409660, registered at: Christodoulou Chatzipavlou, 221, Helios Court, office/apartment 401, 3036, Limassol, Cyprus ("Axlebolt", "we", and derivatives).

Due to the nature of our services, we may inadvertently collect personal data from minors under the age of 16. If you are a minor, please make sure that your parent (legal representative) has read and understood the provisions of this Policy. This Policy is accepted and confirmed by the minor's legal representative on behalf of the minor. If you are a minor and are unable to inform your legal representative of the provisions of this Policy, or if you (your legal representative) do not agree with the terms of this Policy, immediately cease further use of the Website.

If a legal representative allows a minor to use the Website, we assume that said legal representative has read and understood this Policy, as well as accepted the Policy on behalf of the minor.

The Policy, located at creators.standoff2.com/en/privacy-policy, is published on this page in the most up-to-date version. We may unilaterally make changes to the Policy in order to comply with, among other things, the latest changes in applicable legislation and legal precedents. All changes will take effect 15 days after publication. We will make every effort to ensure that the User is notified of the Policy update, but we ask you to check the Website regularly for updates to the current version of the Policy.

Definitions

Contact information is information that the User can share with Axlebolt to obtain reference information and contact the support team, marketing offers, and notifications, as well as to comply with legislation. Said information shall include, among other things, an email address.

Personal data is information or data of any kind that allows you to identify an individual, including Contact Information and Anonymized Analytical Data.

The Creators' Reward Program is a project that allows content creators who create content related to the Standoff 2 mobile game to receive remuneration for creating content based on user interaction with said content. More information: creators.standoff2.com/terms.

Cookies are text files generated by the Website to improve your user experience that are stored on your computer, as well as other similar technologies.

Anonymized analytical data is analytical anonymized information about the User's actions on the Website, the collection and processing of which is aimed at improving the quality of our services.

Applicable legislation refers to legal provisions on the protection of personal data and confidentiality of which you are a subject according to your location or other legal criteria.

Cross-border transfer refers to the transfer of data to a foreign state's territory to an individual or legal entity for the purposes of data processing, including for storage purposes.

What Data, for What Purposes, on What Grounds, and How Long We Process It

Where Did We Get Your Data From?

• From you (from communication, including from completed forms)
• From cookies and other similar technologies installed by our Website in your browser

Who Can We Share Your Data With?

By agreeing to the Policy, you confirm that you agree to the transfer of your data to our affiliate companies and partners who are not our affiliated companies, in accordance with the provisions of this Policy.

We guarantee that the level of personal data protection provided for in contracts concluded with third parties is the same or higher than provided for in this Policy.

We only transfer personal data to third parties for the following purposes:

1) Marketing and business communications

Depending on the nature of your relationship with Axlebolt, we process your personal data to promote our services to you or our partners. For this purpose, we transfer personal data exclusively within the framework of Axlebolt's affiliates and affiliated companies.

2) Quality improvement of the Website and provided services, market research

We enable third-party services to collect your data so that we can provide services to our Users, evaluate, analyze, and improve the Website, and to regularly update and improve our Website and services.

We can use this information to correct any errors on the Website, to assess our Users' demographic information, to find out whether any support is needed for new types of devices for the Website, as well as to determine whether changes to our marketing processes are necessary.

We may provide and use anonymized analytical data so that we can learn more about our visitors and about the effectiveness of the actions we take to attract interest in our Website and related services, as well as the quality of our business projects.

Accordingly, the following categories of personal data may be transferred to the following third parties:

3) Transfer by law

We can also disclose information that you provide so as to respond to subpoenas, requests, notices, court orders, requests from public authorities in any proceedings, as well as to exercise our rights.

We can also disclose your information to defend ourselves against legal claims if we think that information should be disclosed for the purposes of protection of our rights, your safety or safety of other persons, investigation of fraud, or in response to any request from public authorities.

We can transfer your information to investigate, prevent, or take actions with respect to illegal actions, alleged fraud, and situations associated with potential threats to the physical security of any person, or as otherwise required by law.

Your Google data

We do not share or use your data that we have as a result of your use of Google services (including from completed forms or authorization features) for the purposes other than providing the proper operation of Website and improving user-facing features.

Automated Solutions

We do not use automated decision-making, and we do not use your data to automatically assess aspects of your personality (automated profiling, etc.).

Cross-Border Transfer and Data Storage Location

We store data in Germany (Frankfurt), which provides an adequate level of data protection.

By agreeing to the Policy, you consent to your personal data being transferred to the territory of Germany.

Data Security

We make it a priority to ensure safety of your personal data. We follow generally accepted standards to protect your information both at the time of transfer and after it is received. However, no method of communication through the internet is absolutely safe, nor may the method of electronic storage be treated as absolutely safe.

Though no safety system is completely safe, we take safety measures together with our partners to protect against unauthorized access or disclosure of information collected by us. When it comes to Axlebolt, it includes preventing disclosure of your data unless required and ensuring transfer of all information collected by Axlebolt via protected connections, as well as protection and coding by using the appropriate software so as to ensure unauthorized access protection. Our employees and third parties that get access to your data undertake to maintain the confidentiality of your information.

Your Rights

For residents of the European Economic Area (EEA): if you are a resident of the EEA, you have rights under applicable data protection laws. These include, but are not limited to:

• The right of access. You have the right to request and receive a copy of your data at our disposal.
• The right to correction or removal. You have the right to request correction or deletion of your data at our disposal.
• The right to limitation of treatment. 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 (to another controller) at our disposal.

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 process your personal data, you have the right to withdraw your consent at any time. However, please note that this will not affect the legality of your data processing until such consent is revoked.

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, the protection of your rights to privacy, and the protection of your personal and family secrets. In particular, you have the right to:

• require us, as an operator, to clarify your personal data, block, or destroy it if your personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as to take legal measures to protect your rights
• receive information related to the processing of your personal data, including: confirmation of the processing of your personal data by the operator; the legal grounds and purposes of processing your personal data; the purposes and methods used by the operator for processing your personal data; the name and location of the operator, and information about persons (except for the operator's employees) who have access to your 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; the terms of processing of your personal data, including the terms of their storage; information about the performed or proposed cross-border data transfer; title or full name and address of the person processing your personal data on behalf of the operator, if processing is entrusted or will be entrusted to such a person; other information
• protect their rights and legal interests, including compensation for damages and (or) compensation for moral damage in court

For residents of Brazil: if Brazilian legislation applies to the processing of your personal data, you have the right to ask Axlebolt for the following:

• confirmation 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 opportunity to transfer data to another service or product provider through a direct request in accordance with the requirements of the National Data Protection Authority (ANPD) 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 withholding consent and the consequences thereof

You can also withdraw your consent to personal data processing, object to processing carried out on the basis of one of the opt-out situations 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 that affect your interests, including decisions aimed at determining your personal, professional, consumer, and credit profile or other aspects of your personality.

For data subjects in the Republic of Turkey: The Personal Data Protection Law No. 6698 ("PDPL") 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 being used in accordance with said purpose
• find out the third parties to whom your personal data is being transferred within 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 PDPL
• request reports 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 respect of this individual 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 Act ("CCPA") grants California residents the following rights:

The right of access/information. You have the right to request that we provide you with the following information:

• the categories and specific elements of personal data that we have collected about you over the past 12 months
• the categories of sources from which we collect personal data
• the 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
• the categories of personal data that we have sold or transferred, and the categories of third parties to whom each type of personal data has been sold or transferred

The right to removal. You have the right to request that we delete your personal data under certain circumstances, with some exceptions.

The right to correction. You have the right to require us to correct the personal data we hold about you if you believe it to be inaccurate. We may request the relevant documentation 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 said personal data.

The right of refusal.  We do not sell your personal data. However, in any case, you have the right to opt out of the sale and exchange of your personal data.  

If you wish to opt out of said sale and exchange, other than by using 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 to not be discriminated against for exercising the rights set out in the CCPA.

Contact Us

If you wish to exercise the above rights or contact us for any other reason, please contact us at [email protected]. You can also email us at: Christodoulou Chatzipavlou, 221, Helios Court, office/apartment 401, 3036, Limassol, Cyprus.

Please note that in order to fulfill the request, we may require additional information to identify the person who is contacting us. If the provision of said information may violate the rights and legitimate interests of third parties, we may refuse to provide this information.

To exercise the rights mentioned above, your request must contain the following information:

• your email address
• information confirming that you are associated with us, or information otherwise confirming that we are processing your personal data
• your signature, or your representative's signature

You can always contact our data protection officer at [email protected].

Contacting Data Protection Authorities

For residents of the European Economic Area (EEA): if you reside in the European Economic Area 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 the 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 Federal Service for Supervision of Communications, Information Technology, and Mass Media—Roskomnadzor. You can find the contact information via the following link: https://rkn.gov.ru/contacts.

For residents of Brazil: if you believe that our interaction with your personal data violates applicable law, you can submit a request to the Brazilian Data Protection Authority (ANPD).

For residents of California: if you are a CCPA subject, you have the right to file a complaint with the California Data Protection Agency via their email address: [email protected].

For residents of the Republic of Turkey: if you believe that your rights are being violated, you can contact the Personal Data Protection Authority. You can find our contact information here: https://www.kvkk.gov.tr/Icerik/6655/Contact-Us.

Thank you for choosing our services!

Best regards,

The Axlebolt team