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PRIVACY AND COOKIES POLICY

Last updated: 17 April 2023


1. Introduction and Applicability of this Privacy Policy

1.1. In order to enable you to use the Eyestock, your personal data is collected and used by us, APL Publishing Ltd., a Cyprus company having its registered address at Neofytou Nikolaidi & Kilkis, 35, Flat/Office 312, 8011 Paphos, Cyprus, in this document also referred to as "Licensor","our", "us", and "we". Licensor is a data controller meaning APL Publishing Ltd., the subsidiary or affiliated entity of APL Publishing Ltd. that is responsible for the personal information collected and used within the scope of this Privacy and Cookies Policy (the “Privacy Policy”) from our sites and applications.

1.2. This Privacy Policy should be read in conjunction with and in addition to our EULA and other legal documents on the Eyestock for specific categories of Licensees. For the purposes of this Policy, the definitions of Section 1 of the EULA are used.

1.3. This Privacy Policy applies to Eyestock, including the associated Eyestock mobile and desktop applications, eyestock.io and other Eyestock websites (collectively, the “Eyestock”) and other interactions (e.g. customer support) you may have with Licensor, including the processing of any messages, files, video or audio recordings or other content submitted to Licensor. You are strongly encouraged to review the terms of this Privacy Policy before using the Eyestock.

1.4. The services offered by us via the Eyestock can function only if we collect, store, transfer, delete and/or otherwise use specific data relating to you (“personal data” or “data”). Personal data means all information relating to an identified or identifiable natural person such as your name, date of birth, address, or email address.

This Privacy Policy describes what type of data we collect from you and for what purposes we collect and use it when you use the services offered by Us on the Platform. This Privacy Policy also contains important information on the protection of your data, especially the statutory rights you have in connection with it.

1.5. We strive to make the Privacy Policy more accessible and understandable, for this we:

  • section information,

  • use tables to structure information,

  • capitalize terms that are used more than once.

1.6. We do not verify the information we receive from you, unless such verification is necessary for us to fulfill our obligations to you. However, we assume that you provide true and sufficient information about yourself and keep it up to date.


2. Processing, Storage and Transfer of your Personal Data


2.1. The processing of personal data on the Eyestock is carried out using automation tools.

2.2. The categories of personal data subjects include:

2.2.1. Licensee:


List of personal data

Types of personal data processing

Basis for Processing

Purpose of processing

Source of personal data

Period of storage of personal data


Transfer of personal data

Name

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

EULA

Operation of the Eyestock (Applies to the operation of the Eyestock)

Filling out forms via Eyestock

1 year

No

E-mail address

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

EULA

Operation of the Eyestock (Applies to the operation of the Eyestock)

Filling out forms via Eyestock

1 year

No

Licensee Eyestock ID

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

EULA

Operation of the Eyestock (Applies to the operation of the Eyestock)

Filling out forms via Eyestock

1 year

No

Actions in the Eyestock

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

Consent

Marketing (Used to serve targeted ads and marketing messages or measure ad performance)

Weblogs

1 year

No

Search history in the Eyestock

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

EULA

Analytics (Used to collect data about how users interact with the application and its performance)

Weblogs

1 year

No

Other Content Created by Licensee

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

EULA

Analytics (Used to collect data about how users interact with the application and its performance)

Weblogs

1 year

No

Bug reports

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

EULA

Fraud prevention, security

Weblogs

1 year

No

Approximate location

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

Consent

Marketing (Used to provide targeted ads and marketing messages or measure ad performance)

Licensee's computer

1 year

Yandex Metrica (Yandex LLC)

Device IDs or other identifiers

Collecting, recording, organizing, structuring, storing, using, combining, erasing, and destroying data

Consent

Marketing (Used to provide targeted ads and marketing messages or measure ad performance)

Licensee's computer

1 year

Yandex Metrica (Yandex LLC)



Cookies and Similar Technologies

In order for the Eyestock to function properly, we may use cookies. Cookies are small pieces of stored text information that are automatically created and stored on your computer or other device to associate and identify Licensee's activity ("Cookies"). Cookies generally do not include names and/or email addresses and/or other personal data. In fact, they usually contain anonymous information necessary to improve the functionality of the Game.

We use the following cookies:

Domain

Cookie name

Lifespan

Function type

https://eyestock.io/

eyestock_refresh_token

1 month

Service access token, generated and updated during registration and interaction with the Eyestock

https://eyestock.io/

login_status

1 month

Authorization data of the Licensee


2.3. Personal data is stored electronically in the Eyestock’s information system, as well as in archival copies of the Eyestock’s databases.

Personal data on paper is not stored.

When storing personal data, organizational and technical measures are taken to ensure the safety and exclude unauthorized access to the personal data.

2.4. External recipient of personal data:

System

Function type

Control method

 Yandex.Metrica

Performance, analytics and research. We use Yandex.Metrica to better understand how you use our products.

For more information on privacy practices Yandex.Metrica cm.https://yandex.com/legal/metrica_termsofuse. Find out more in theirTerms of Use andPrivacy Policy.

Refusal of processing:visit the Yandex Metrica page.


3. Your Rights


3.1. Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you have the right at any time:

  • to be informed of the data we collect and use and to request access or demand a copy of the data concerned (right to access);

  • to demand the correction of inaccurate data and, subject to the nature of the collection and use, the completion of incomplete data (right to rectification);

  • subject to just cause, to demand the deletion of your data (right to deletion);

  • to demand that the collection and use of your data be restricted, provided the legal criteria are met (right to restrict processing);

  • subject to the legal criteria being met, to receive the data you have provided in a structured, current and machine-readable form and to transfer this data to another data controller or, when technically feasible, to have it transferred by Licensor (right to data portability);

  • to object to the collection and use of data – only where the collection and use is based on a task carried out in the public interest or in the exercise of a vested official authority (Art. 6 (1)(e) of GDPR) or legitimate interest (Art. 6 (1)(f) of GDPR), including profiling, based on the same data collection and use grounds as explained in other sections of this statement (right to object). You also have the right to object to the collection of your personal data for direct marketing purposes at any time;

  • to revoke any permission, you have granted us at any time. Such revocation will not affect the legality of collection and use carried out prior to the revocation and is based on the permission granted;

  • not to receive discriminatory treatment while exercising your rights.

3.2. To exercise any of the rights specified in this section, you can contact us and submit your request using the contact information from section 5 “Contact Us” below. 


4. Data Security

4.1. The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.


5. Contact Us

5.1. If you have any questions about how your personal data is collected, stored, used or otherwise processed, or if you would like to exercise any of your data rights, please contact us at:

APL Publishing Ltd.

Neofytou Nikolaidi & Kilkis, 35, Flat/Office 312, 8011 Paphos, Cyprus

Contact Email:support@eyestock.io

5.2. If you exercise your statutory rights regarding your data, we will collect and use the data contained in your request in addition to any other personal data held by Lisensor for the purpose of examining the request, responding to it and, when necessary, taking necessary action. We base such collection and use on a legitimate interest to exercise our members’ rights (Art. 6 (1) (f) of the GDPR). Personal data collected and used for this purpose are kept for two (2) years from the day we respond to your request. We cannot fulfill your request to delete or to know and access your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, we may ask that you provide the following personal information when you submit your request:

  1. Full name;

  2. Username;

  3. Email address.

5.3. Your requests may be restricted in some cases, such as when your request is about disclosure of information about another person, or if you ask us to delete information that we may process under the law regardless of your consent.

5.4. You may need to provide additional information as part of your responses to our identity verification questions. We will only use this information to confirm your identity. Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.

In most cases, we will comply with your request within one calendar month, provided that we have all required information from you. If we are unable to fully satisfy your request within a calendar month (due to the complexity or number of requests), we may extend this period for an additional two calendar months, unless otherwise prohibited by applicable law. If an extension is necessary, we will explain the reasons for the delay. If you make your request electronically, we will provide the relevant information electronically to the extent possible, unless you request otherwise.


6. Changing the Privacy Policy


6.1. The current version of the Privacy Policy is published at: https://eyestock.io/

6.2. Licensor may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We encourage you to review this Privacy Policy when you use the Eyestock to be aware of our Privacy Policy and how you can protect your privacy. If we make changes that materially alter your privacy rights, Licensor will provide additional notice, such as via email or through the Eyestock. If you disagree with the changes to this Privacy Policy, you should deactivate your account.