Hazerim Interactive Entertainment, UAB, legal entity code 304843912, Ukmergės g. 228A-8, LT-07161 Vilnius, Lithuania (hereinafter referred to as the Company) commits to ensure the security of users personal data and protection of rights when users use and navigate the Company’s website https://hazerim.com (hereinafter referred to as the Platform).

This privacy policy (hereinafter referred to as the Privacy Policy) specifies the data collected by the Company, means and sources wherefrom this data is obtained, legal basis for processing of personal data as well as actions and measures, which have been taken by the Company to protect the collected data.

By using the Platform, Users shall agree to the terms of this Privacy Policy.

All personal data are processed in accordance with data protection and privacy laws, including General Data Protection Regulation (EU) 2016/679.

For any questions regarding this privacy policy or any requests regarding the processing of personal data, please contact us at: contact (at) hazerim (dot) com.

1. USE AND COLLECTION OF PERSONAL DATA

1.1. The data controller, data processors, and scope of the privacy policy

Personal data provided on or through the Platformare managed and controlled by the Company.

This Privacy Policy applies to any application or platform managed by the Company and to any service provided by the Company.

This Privacy Policy applies to all users of the Platform (hereinafter referred to as the User or User). This Privacy Policy does not apply to links to websites provided by third parties on our Platform, therefore we recommend that the User directly and individually consult the privacy policies or policies applicable to such third-party websites or services.

To ensure the operation of the Platform the Company may engage third parties in the processing of User’s personal data and, for this purpose, transfer their personal data to other legal entities, complying with the conditions set forth in this Privacy Policy.

1.2 Collected information

Technical information, cookies

The goal of our Platform is to obtain certain data and convert it into the best experience using the Platform, grant the User possibility to use all the benefits of the Platform. To reach the goal, each time, after installing it, User uses our Platform, We automatically collect and manage some or all of the following technical personal data:

• IP address:
• Date and time of access;
• the name and URL of the page that connects to the Platform;
• User’s device operating system data;
• information of the User’s internet provider;
• User’s geo-location data, language settings;
• Other relevant technical information.

Please note, all the above-mentioned personal data we collect is encrypted. Without collection and processing of the said information Platform’s operation may not be ensured.

The Company also collects and manages the technical data of the Users using cookies. To learn more about cookies and processing of personal data, see the Company’s Cookie Policy.

Information, provided by the User

The Company may also collect and process other personal data of the User, provided on its own initiative by e-mail or another information system available on the Platform. Such personal data may include:

• User’s name, surname;
• contact information (telephone, e-mail address, home address);
• other personal information identifying the User;
• content of the request, report, complaint or any other relevant message.

Provision of the mentioned data by the User itself is equal to consent. The consent can always be revoked by reaching the Company on the email contact (at) hazerim (dot) com.

Please note, all the above-mentioned personal data we collect is encrypted. Without collection and processing of the said information Platform’s operation may not be ensured.

The above list is not exhaustive, the Company may need to collect additional information in special cases, which depends on the reason of the User’s request, or in other cases, where it is required to achieve the objectives of this Privacy Policy. If it would be needed, the Company will ask the consent of the User to collect additional information.

The Platform will ask for User’s to grant:

• Camera permissions. It is needed to allow the User to open and use a QR scanner for authentication.
• Location permissions. It is needed to enable location tracking. Please note that all of it is encrypted and inaccessible by the Company. 
• Fitness/accelerometer permissions contribute to the location tracking mechanisms as they are used to efficiently engage GPS whenever the User’s phone moves.

1.3. Use of personal data

The main purpose of the processing of personal data is to enable efficient, optimal and adapted use of the Platform for the personal needs of the User. The main goal of the Platform cannot be reached without obtaining the following personal data. Personal data is used:

• for convenient, efficient and functional use of the User’s needs;
• to ensure smooth administration of the Platform;
• to ensure functionality of the Platform;
• to ensure timely and appropriate processing of User’s queries, requests, and replies;
• to contact User regarding any information he/she provides;
• to enable the Company to perform statistical and other analysis by continuously improving the content of the Platform and the services provided by the Company;
• for other purposes disclosed to the User at the time of submitting personal data.

Use of personal data for direct marketing purposes

The Company also handles and processes your personal data for direct marketing purposes in the following cases:

• when we obtain your explicit consent to such processing (the basis for the processing is consent);
• when you are the Company’s client without expressly objecting to processing your data for direct marketing purposes, marketing of similar services, where the client has been duly notified of such processing beforehand (the basis of the processing is the legitimate interest of the Company).

For the purposes of direct marketing, the Company processes the following personal data: your name, email address, phone number.

Your personal data for direct marketing purposes can be processed in the following ways:

• you may receive a newsletter with our offers, promotions, products and news by e-mail;
• you may receive invitations to events and similar information by e-mail;
• you may be called by phone with invitation, proposal or offer.

We inform you that you are free to opt out of our newsletters at any time. You can do this by clicking on a link for that purpose at the bottom of our e-mail with the newsletters.

You may at any time refuse to receive information about events or any other information from us by sending an email to contact (at) hazerim (dot) com.

1.4. Storage of the personal data

User’s personal data will not be processed beyond what is necessary for the purposes laid down in this Privacy Policy.

Personal data collected through the Platform will be stored for no longer than 3 years.

Your personal data processed for the purposes of direct marketing will be stored for 2 years from the date of the consent (if we have received a separate consent) or the date of completion or expiration of the relevant contract.

Longer periods of personal data retention may be applied where:

• there is a reasonable suspicion of an unlawful act which is subject to investigation;
• User’s data is necessary for the proper resolution of the dispute, complaint or claim;
• the Company has received complaints related to the User or if the Company has noticed any violations committed by the User;
• it is necessary for back-up copies or related purposes of functioning of information systems of the Company;
• it is mandatorily required by applicable laws.

Your personal data will be destroyed within a reasonable time after the specified deadline.

1.5. The legal basis for the processing of personal data

The Company controls and processes User’s personal data:

• on the basis of consent, which is expressed by User’s active actions, e.g. referrals to the Company and submission of personal data, other active actions;
• exercise of the Company’s legitimate interests (for example, managing and administering a Website, etc.);
• in order to comply with other legal obligations.

Users may revoke their consent to process their personal data at any time. If the Company has no other legal basis for the processing of personal data, the Company will cease processing of personal data immediately after the cancellation / revocation of the consent provided by the User. The consent can always be revoked by reaching the Company on the email contact (at) hazerim (dot) com.

1.6. Data transmission to third parties

The Company does not transfer Users personal data to any third parties without prior User’s consent, except as described below.

In the light of investigations or other cases provided by law, personal data may be submitted to the law enforcement, judicial or pre-trial institutions without any specific consent of the User.

In addition, particular technical data pertaining to the Users’’ visits on the Platform (such as IP address, data collected or placed on the devices of the Users by the cookies, technical information of the browser, other information related to User’s browsing activities, etc.) may be transferred or made available to the entities in the EEA as well as outside the EEA (e.g., we use the Google Analytics service) for the purposes related to statistics, analysis and other related purposes. Please note that the personal data in non-EU countries may be subject to less protection than the EU. The Company will carefully assess the conditions under which such data will be processed and stored after transfer to the above entities.

The Company also uses the services provided by third parties (such as third-party data centres, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, etc.) that may require access to the User’s personal data to the appropriate extent. In this case, the Company ensures that the data processors comply with the obligations of confidentiality and adequate personal data protection.

2. THE RIGHTS OF THE USERS

Users have certain rights related to the protection of their personal data. These rights are:

• the right of access to the personal data;
• the right to rectification;
• the right to erasure (right to be forgotten);
• the right to restriction of processing;
• the right to data portability;
• the right to object;
• in case the User deems that his/her rights have been violated, he/she has the right to lodge a complaint with a data protection supervisory authority.

3. DATA SECURITY

By implementing appropriate technical and organizational measures, the Company protects User’s personal data from loss, misuse, unauthorized access, disclosure or alteration.

The Company recommends that the Users comply with the following minimum safeguards for their personal data protection:

• do not visit suspicious websites;
• update their software and anti-virus protection as recommended by software providers and vendors.

4. FINAL PROVISIONS

This Privacy Policy applies from 01 January 2022.

This Privacy Policy may be from time to time updated by the Company. The Company will inform Users about the updates by submitting a new version of the Privacy Policy along with the dates of the corrections made.

Users understand and accept that by continuing to use the Platform, they agree to any changes or updates to the Privacy Policy.

If any provision of the Privacy Policy is deemed void or inapplicable, such provision shall not affect the legality and validity of the remaining provisions of the Privacy Policy.