1. WHAT DOES THIS PRIVACY
POLICY COVER?
This Privacy Policy applies to the
personal data that We collect and
process acknowledging and
understanding that Your privacy is
important to You and that You care
about how Your personal data is
collected and processed. We at
SERVGLOW LIMITED are dedicated to
safeguarding and preserving Your
personal data and privacy when
visiting Our Websites, utilizing Our
services, products or communicating
electronically with Us. For the
purposes of the data protection laws
that apply to us, including the GDPR
which is the European General Data
Protection Regulation and Canada
Data Protection Law, We act as the
Data Controller for the personal
data that We collect and process to
enable You to make use of Our
Services. The purpose of this
Privacy Policy is to transparently
provide You with an explanation as
to the legal basis for Us collecting
and processing Your personal data,
the categories of personal data that
We may collect about you, what
happens to the personal data that We
may collect, where We process Your
personal data, how long We are
required to retain Your personal
data, who We may share Your personal
data with and to also explain Your
rights as a data subject. We do
update this Privacy Policy from time
to time and will post all updates to
Our Website as and when issued.
Please do review this policy
regularly on Our Website for any
changes.
2. DEFINITIONS AND
INTERPRETATIONS
In this Privacy Policy the following
terms shall have the following meanings:
Cookie
means a small text file placed on Your
computer or device by Our Websites when
You visit certain parts of Websites.
GDPR
means the General Data Protection
Regulation (EU) 2016/679, of the
European Parliament and of the Council
of 27 April 2016 on the protection of
natural persons with regard to the
processing of Personal Data and on the
free movement of such data, and
repealing Directive 95/46/EC, as
amended, replaced or superseded and in
force from time to time and as
transposed into member-state
legislation.
Privacy Policy
means this Privacy Policy updated from
time to time and made public on Our
Websites.
Personal Data
means any information which relates to
an identified or identifiable natural
person. An identifiable person is one
who can be identified directly or
indirectly in particular by reference to
an identifier such as a name, an
identification number, location data, an
online identifier or to one or more
factors specific to the physical,
physiological, genetic, mental,
economic, cultural or social identity of
that natural person.
Website
means the website, which is owned by the
Company.
Services
mean all Our products: Website or other.
You? Your
You, as User or Guest, depending on your
status at the Website.
We, Us, Our
refers to SERVGLOW LIMITED.
3. YOUR DATA PROTECTION
RIGHTS
Under the GDPR you, as a data subject,
have certain rights over the personal
data that We hold and process.
At SERVGLOW LIMITED, We are committed to
make it easy for You to exercise these
rights in the most transparent manner
possible. You can exercise any of Your
rights in relation to the data that
SERVGLOW LIMITED holds about you, by
contacting Our data protection officer
through the email address provided at
the end of this section or through Your
personal user cabinet.
The following are the specific rights
You have over Your personal data We hold
and process, namely:
a. The right to be informed about
Our collection and processing of Your
personal data including without
limitation the legal basis for the
collection and processing, the
categories of data, the methods of data
use, the envisaged period for which the
personal data will be retained. This
Privacy Policy should tell You
everything You need to know, but You can
always contact Us to find out more or to
ask any questions.
b. The right to access Your
personal data We collect about you,
commonly referred to as "Subject Access
Requests", which provides you, as the
data subject, the right to obtain a copy
of Your personal data that We are
processing for You Pursuant to GDPR We
are required to respond without undue
delay to all Subject Access Requests in
practice this means We have to respond
within 1 month of receipt of the Subject
Access Request. Ordinarily Subject
Access Requests are free of charge. We
may extend the time period for
responding to a Subject Access Request
by a further two months and may charge a
reasonable fee if We deem the request to
be manifestly unfounded or excessive,
however, We are required to advise You
of Our intention to do this within 1
month of Your subject access request.
Should You wish to make a Subject Access
Request this can be done by contacting
the Company using the contact details in
Section 9.
c. The right to have Your personal
data rectified
if any of Your personal data that We
collect and process is in any way
inaccurate or incomplete.
d. The right of erasure (otherwise
known as “the right to be
forgotten”), i.e. the right to ask Us to delete or
otherwise dispose of any of Your
personal data that We process. Please
note that this is not an absolute right
and We may not be able to comply with
Your request as We may be legally
obliged to continue to retain Your
personal data for a specific period
e. The right to restrict (i.e.
prevent) the processing of Your personal
data by us.
f. The right to object to Us
processing Your personal data for a
particular purpose or purposes. Please
note that the right to object only
applies in certain circumstances and
will depend on the purposes or legal
basis for the processing.\
g. The right to data portability.
This only applies where You have
provided personal data to Us directly,
the legal basis for Us processing Your
personal data is i) consent or ii) for
the performance of a contract and We are
processing Your data using automated
means. In such instances You have the
right to receive Your personal data (or
request that We transfer it to another
Controller) in a structured, commonly
used and machine-readable format.
h. Rights relating to automated
decision-making and profiling. We do not use Your personal data in
this way.
i. The right to lodge a complaint
with any relevant Data Protection
Authority, in particular in the member
State of Your residence, place of work
or the place of processing Your personal
data.
Data Subject Request
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision
making and profiling.
j. If You wish to exercise any of
the aforementioned rights, please
contact Us. We request that in the first
instance You contact Our data protection
officer at any time Our on
[email protected]
k. We promise to promptly
consider Your request and to respond to
You in accordance with the requirements
of the Canada Data Protection Act and
GDPR.
l. Complaints to the Canada Data
Protection Inspectorate should be made
by using the appropriate forms provided
in the Canada Data Protection
Inspectorate Website.
4. PERSONAL DATA WE COLLECT
ABOUT YOU
4.1. PRINCIPLES OF PROCESSING
During collecting and processing the
personal data, the Company adheres the
principles as follows:
j. Lawfulness, fairness and
transparency
Lawfulness – the controller
identifies a lawful basis before to
process the personal data (for
example consent). Fairness – in
order to process fairly, the
controller has to make certain
information available to the data
subjects as practicable. This
applies whether the personal data
was obtained directly from the data
subjects or from other sources.
Transparency – any information and
communication relating to the
processing of the personal data be
easily accessible and easy to
understand, and that clear and plain
language be used.
k. Purpose limitation
The personal data must be collected
for specified, explicit and
legitimate purposes and not further
processed in a manner that is
incompatible with those purposes;
further processing for archiving
purposes in the public interest,
scientific or historical research
purposes or statistical purposes
shall, not be considered to be
incompatible with the initial
purposes.
l. Data minimization
The personal data must be adequate,
relevant and limited to what is
necessary in relation to the
purposes for which they are
processed.
m. Accuracy
The personal data must be accurate
and, where necessary, kept up to
date; every reasonable step must be
taken to ensure that personal data
that are inaccurate, having regard
to the purposes for which they are
processed, are erased or rectified
without delay.
n.Storage limitation
The personal data must be kept in a
form which permits identification of
data subjects for no longer than is
necessary for the purposes for which
the personal data are processed.
Personal data may be stored for
longer periods insofar as the
personal data will be processed
solely for archiving purposes in the
public interest, scientific or
historical research purposes or
statistical purposes, if only are
implemented appropriate technical
and organizational measures required
by governing law in order to
safeguard the rights and freedoms of
the data subject.
o.Integrity and confidentiality
The personal data must be processed
in a manner that ensures appropriate
security of the personal data,
including protection against
unauthorized or unlawful processing
and against accidental loss,
destruction or damage, using
appropriate technical or
organizational measures.
4.2. LEGAL BASIS FOR COLLECTING AND
PROCESSING PERSONAL DATA
SERVGLOW LIMITED will process Your
personal data based on legal bases
such as:-
a. the performance of Our contract
with You (i.e. the provision of Our
Services to you);
b. our legitimate business interests
(i.e. for fraud prevention,
maintaining the security of Our
network and services, seeking to
improve the Services that We provide
and Your interaction with us).
Whenever We rely upon on this lawful
basis, We assess Our business
interests to make sure that they do
not override Your rights.
Furthermore, in some cases You have
the right to object to this
processing;
c. with Your consent for direct
marketing purposes so that We may
keep You fully up to date with other
products and services that We supply
and think may be of interest to you.
Where We rely upon consent, We will
need Your explicit consent, which
may be removed at any time;
d. our legal obligation.
4.3. CATEGORIES OF THE PERSONAL
DATA WE COLLECT
A summary of the Personal Data that
We process, when We collect it, how
We use it and why We use it (i.e.
the legal basis for processing) is
listed below:
|
Personal Data
|
When We Collect
|
How We Use
|
Why We Use
|
|
Steam ID, nickname,
avatar
|
In registration
procedure
|
We use Your personal
and contact
information to
register You as a
User and identify
You in Our Services.
|
Necessary for the
performance of a
contract with you
|
| Email |
In registration
procedure, in event
registration
|
Use email to restore
Your account. We use
it to notify You
about changes to Our
Terms or Privacy
Policy; to
communicate with you
|
Necessary for the
performance of a
contract with you
|
|
Information about
Your transactions
|
When You do the
transaction
|
We use it for make
transactions. All
transactions are
carried out using
third-party services
|
Necessary to comply
with a legal
obligation
|
| Service id |
When You use Our
services
|
We use it to
optimise Our service
and to improve Our
Website, services,
direct marketing,
User relationships,
behaviour profiling
and experiences
|
Necessary for Our
legitimate interests
|
5. PROTECTING YOUR PERSONAL
DATA AND DATA RETENTION
We use, store and process Your
personal data on SERVGLOW LIMITED
servers which are located on the
Netherlands. By filling a “consent
application” You agree to these
conditions of collection,
processing, transfer and storing
Your personal data. When We process
Your personal data for one of the
legal bases specified in this
Privacy Policy, We will take all
steps reasonably necessary to ensure
that Your Personal Data is treated
securely and in accordance with this
Policy. SERVGLOW LIMITED protect
Your Personal Data under
internationally acknowledged
standards, using physical,
technical, and administrative
security measures to reduce the
risks of loss, misuse, unauthorized
access, disclosure, and alteration.
Some of the safeguards SERVGLOW
LIMITED use are firewalls and data
encryption, physical access controls
to Our data centers, and information
access authorization controls.
SERVGLOW LIMITED also authorize
access to Personal Data only for
those employees or contractors who
require it to fulfill their job or
service responsibilities. The
SERVGLOW LIMITED’s staff is trained
on procedures for the management of
personal information, including
limitations on the release of
information. Access to personal
information is limited to those
members of Our staff and contractors
whose work requires such access.
SERVGLOW LIMITED conducts periodic
reviews to ensure that proper
information management policies and
procedures are understood and
followed. All of Our physical,
electronic, and procedural
safeguards are designed to comply
with applicable laws and
regulations.
5.1. HOW WE PROTECT YOUR DATA
When You provide Your personal data
through Our Website, KYC portals,
Our applications, this information
is transmitted across the internet
securely using industry standard
encryption. Your personal data will
be held encrypted on secure servers.
Where any third parties process Your
personal data on Our behalf, We
require that they have appropriate
technical and organizational
measures in place to protect this
personal data and We will also
ensure that a GDPR compliant. Data
Processing Agreement is in place
between SERVGLOW LIMITED and the
third party so that both parties
understand their responsibilities
and liabilities pursuant to GDPR.
5.2. HOW YOU CAN PROTECT YOUR
PERSONAL DATA
When You create Your account, choose
a strong password that is unique to
this account. Do not share Your
password with other people. Using
the same password across Your
different accounts will increase the
risk of Your data being compromised
if Your password is accidentally or
unlawfully accessed by unauthorized
persons. If You suspect that someone
else has got access to Your
password, make sure that You change
it immediately. When using Our
wallets, ensure You keep Your
passphrases and keys in a secure
device isolated from devices You use
regularly. Do not share the device
containing Your passphrases and keys
with friends, family members or even
people You trust.
5.3. DATA RETENTION
Your personal data will be retained
for as long as necessary to satisfy
the purposes We received it for,
this includes regulatory and
business purposes.
In determining the necessary
personal data retention period, the
following factors are considered:
a. The amount of personal data as We
aim to minimize this amount to the
extent possible for each specific
purpose specified in Section 4.2 of
this Privacy Policy.
b. The nature of the personal data
depending on the exact purpose which
this specific personal data serves
as detailed in Section 4.2 of this
Privacy Policy.
c. The sensitivity of the personal
data by its nature and substance.
d. The potential risk of harm from
unauthorized use or disclosure of
Your personal data and We continue
to run risk assessments and risk
mitigation activities to minimize
this potential risk including
engagement of third-party
specialized data management and data
protection providers.
e. The purposes for which We process
Your personal data and whether We
can achieve those purposes through
other means, and the applicable
legal requirements.
6. THIRD PARTY LINKS
You may find links to third party
Websites on Our Website or chats of
users contained on Our Website or
mobile applications. These Websites
should have their own privacy
policies which You should check. We
do not accept any responsibility or
liability for their policies
whatsoever as We have no control
over them.
7. WHO DO WE SHARE YOUR PERSONAL
DATA WITH?
We do not share Your Personal Data
to third Parties, except cases that
are mentioned in this Privacy
Policy.
7.1 WITH YOUR CONSENT
We will share information with
companies, organizations or
individuals outside of SERVGLOW
LIMITED when We have Your explicit
consent.
7.2 TO COMPLY WITH THE LAW
We may share information in response
to a request for information if We
believe disclosure is in accordance
with, or required by, any applicable
law, regulation, legal process or
governmental request, including, but
not limited to, meeting national
security or law enforcement
requirements. To the extent the law
allows it, We will attempt to
provide You with prior notice before
disclosing Your information in
response to such a request.
7.3 IN AN EMERGENCY
We may share information if We
believe that it's necessary to
protect the vital interests of the
data subject (i.e. to prevent
imminent serious physical harm or
death to a person.)
7.4 TO ENFORCE OUR POLICIES AND
RIGHTS
We may share information if We
believe Your actions are
inconsistent with Our user
agreements, rules, or other SERVGLOW
LIMITED policies, or to protect the
rights, property, and safety of
ourselves and others.
7.5 WITH OUR AFFILIATES
We may share information between and
among SERVGLOW LIMITED and any of
Our parents, affiliates,
subsidiaries, and other companies
under common control and ownership.
7.6 WITH OUR PARTNERS
We may share information with
vendors, consultants, and other
service providers (but not with
advertisers and ad partners) who
need access to such information to
carry out processing activities for
us. The partner’s use of personal
data will be subject to appropriate
confidentiality and security
measures. We may share Your private
personal data with such service
providers subject to obligations
consistent with this Privacy Policy
and any other appropriate
confidentiality and security
measures, and on the condition that
the third parties use Your private
personal data only on Our behalf and
pursuant to Our instructions. We may
share Your private personal data
with our partners to make a
transaction. Where any third parties
process Your personal data on Our
behalf, We require that they have
appropriate technical and
organizational measures in place to
protect this personal data and We
will also ensure that a GDPR
compliant. Data Processing Agreement
is in place between SERVGLOW LIMITED
and the third party so that both
parties understand their
responsibilities and liabilities
pursuant to GDPR.
7.7 INTERNATIONAL TRANSFERS OF
PERSONAL DATA
Data Subjects risk losing the
protection of GDPR if personal data
is transferred outside of i) the EEA
or ii) countries holding adequacy
status and accordingly GDPR
restricts such transfers, unless the
rights of data subjects in respect
of their personal data is protected
by appropriate safeguards or one of
a limited number of exceptions
applies (such exceptions include
Your explicit and informed consent).
SERVGLOW LIMITED will not make any
international transfers of Your
personal data unless it has i) Your
explicit and informed consent or ii)
it has put in place the appropriate
safeguards or iii) the international
transfer is covered by an exception.
7.8 ADVERTISING, ANALYTICS AND
BUSINESS PARTNERS (LIMITED TO
NON-PERSONALLY IDENTIFIABLE
INFORMATION)
We may share aggregated or
pseudonymous information (including
demographic information) with
partners, such as publishers,
advertisers, measurement analytics,
apps, or other companies. For
example, We may tell an advertiser
how its ads performed or report how
many people installed an app after
seeing a promotion. We do not share
information that personally
identifies You (personally
identifiable information is
information like name or email
address) with these partners, such
as publishers, advertisers,
measurement analytics, apps, or
other companies.
7.9 OTHER INFORMATION
Other information, that does not
personally identify You as an
individual is collected by SERVGLOW
LIMITED (such as, by way of example,
patterns of use) and is exclusively
owned by SERVGLOW LIMITED. We can
use this information in such manner
that SERVGLOW LIMITED, in its sole
discretion, deems appropriate. We
may share specific aggregated,
non-personal information with third
parties, such as the number of users
who have registered with us, the
volume and pattern of traffic to and
within the site, etc. That
information will not identify you,
the individual, in any way. We shall
not use Your email or other contact
information for sending of
commercial proposal, other marketing
needs, without Your prior consent.
In the light of the above, when You
send Us messages, We can keep them
for administering of Your inquiries,
for improving of Our services. We
shall not transfer information from
such messages to third parties.
USE OF COOKIES
To enhance the quality of Our
services, provide You with relevant
content as well as understanding how
You use Our Website and
applications, We use technologies,
such as Cookies. Cookies do not
typically contain any information
that personally identifies you, but
personal information that We store
about You may be linked to the
information stored in and obtained
from Cookies. We use Strictly
Necessary Cookies - these are
required for the operation of Our
Website. They include User session
key, browser language. This is a
temporary key issued to the User
after the successful logging in.
These cookies are used to enable You
to log into secure areas of Our
Website.
CONTACTING US
We welcome any queries, comments or
requests You may have regarding this
Privacy Policy. If You wish to make
a subject access request, please do
not hesitate to contact Us at
[email protected]
CHANGES TO THIS PRIVACY POLICY
Any changes that We make to Our
Privacy Policy in the future will be
posted on Our Website. Where
appropriate, We will notify You of
the changes when You next visit Our
Website. This Privacy Policy was
last updated on
