The rules published herein disclose our policy ("Policy") concerning the personal data, which INOVENTO collects through the website www.inovento.com ("Website"), the social networks and other platforms in connection with the provision of online games, services, software and other applications and resources ( "Services") , including personal data of user and profile sites or in connection with the participation in forums, blogs, sharing, downloading and uploading any kind of user and other media content ("Content"). The participants in the games of INOVENTO, the visitors of the website and the social networks and all registered users of the Services and the Content, which is property of INOVENTO shall be referred to as ("Users") everywhere.
The collection, processing and storing of personal data of the Users of the Services shall be carried out by INOVENTO LLC ("INOVENTO", “Controller”, “We”, “Us”) in its capacity of a personal data controller, holding certificate No 373452, which is duly registered in the relevant registers maintained by the Bulgarian Commission on Personal Data Protection (CPDP).
INOVENTO administers the personal data in compliance with the requirements of the Bulgarian Law on Personal Data Protection and other applicable regulations of the Bulgarian and European law. Personal data are collected, processed and stored legally and in good faith, only for the purpose of provision of the Services through the website www.inovento.com, the social networks and the other platforms where they are accessible.
Entry into effect: May 25th, 2018.
Please read this Policy carefully before accessing the Website or its Services. If you disagree with any of the terms, you should not access the Website or its Services in any way or form.
The protection of your personal data is our main duty and priority in the service provision - online games and other resources, referred to as the "Services".
1. WHO ARE WE?
INOVENTO LLC is a company duly incorporated and operating according to the law of the Republic of Bulgaria with seat and registered address at 1712 Sofia, Mladost district, block 355, entrance 2, ap. 5 and UIC 201429823.
2. VALIDITY AND EFFECT
This Policy determines what happens to your personal data that you provide through the Website.
This Policy is an integral part of our Terms of Conditions for the use of the Website (“Terms and Conditions”), available here. All definitions provided in the Terms and Conditions are applicable in the hereby Policy as well.
We reserve our right to make amendments to this Policy at any given time at our own discretion. The new versions will be published on the Website. In case that you are a registered user, you will be notified by email for such changes.
In case you disagree with the changes you should notify us in writing, after which your Account and all information stored about you will be deleted. In case you agree with the changes, you should provide us with your explicit, freely given, specific, informed and unambiguous consent with the amendments made before you continue using the Website and its Services.
The access to this Policy is always available at the following address: http://www.inovento.com/legal/privacy.html.
“Personal data” is all data which contains identifiable information (e.g. name, address, telephone number, email, etc.). Before we collect and process your personal data we must receive your explicit, freely given, specific, informed and unambiguous consent.
The Policy published herein is applicable and valid only for users of the services of INOVENTO, available through the Website, the social networks and other platforms. This Policy does not apply to social networks, other websites, platforms or companies, which INOVENTO does not control but which give a link to or are connected directly or indirectly with the provided Services. You should be informed that those websites, platforms and companies have their own policies for the protection of personal data, for which we are not liable. You should become acquainted with the privacy policies of those other websites, platforms and companies before providing your personal data to them.
3. DATA WE COLLECT ABOUT YOU
3.1. DATA PROVIDED BY YOU
When you register to use our services, you may be asked to provide information, which will be used only for the provided Services and Content. You may be asked to provide your:
Location (state, city, settlement);
Preferred language for communications;
A part of the information is mandatory for the creation of a user account and the other part is optional. This is indicated in the Registration Form.
3.2. DATA WE COLLECT AUTOMATICALLY
Each time you visit the Website, we will automatically collect the following data:
We collect device-specific information (such as your hardware model, operating system version, unique device identifiers.
When you use the Website or Services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and cell towers. Your location data are used to show you Items based in your city/country and are also used for any delivery services you opt to use in-app.
We collect technical details, including the Internet Protocol (IP) address of the device you are using to connect to the Internet, time zone, operating system.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
This website uses the following types of cookies:
“session cookies” which are erased when the user closes the browser;
“persistent cookies” which remain on the user's computer/device for a pre-defined period of time;
“first-party cookies” which are set by the web server of the visited page and share the same domain;
4. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
We need the collected personal data to contact you in order to provide services with the highest possible quality to you as a registered user identified through the data provided with the registration in order to get feedback about the quality of our games and services, proposals for their improvement and also in order to provide to you prompt technical and other support, where necessary.
WE USE THE PROVIDED DATA, AS FOLLOWS:
To establish the availability and the compliance with the minimum system, technical, software and other requirements for your successful access to our products and services.
To provide you reliably our products and services by verification of your access rights with regard to the orders and paid products and services, as well as for the free versions, modifications and products.
To improve permanently the quality of our games, products and services by receiving the questionnaires filled in and sent by you, surveys, proposals, advices and ideas for improvement of the existing and the launching of new products and services through our website or other platforms.
To offer you new products, games, services, updated versions, upgrades, special proposals and discounts.
To send to you news, e-bulletins, promotions, offers, interesting and useful information and other novelties.
To provide to you specialized information about the adequate use and access to our Services, with instructions, guidelines and other useful content through the obtained data for your language and other preferences, location, telephones and other contact details.
To invite you to take part in questionnaires and surveys of the opinion of users about the quality and the satisfaction with the offered Services and our website.
WE DO NOT COLLECT PERSONAL DATA, WHICH:
disclose race or ethnic origin;
disclose political, religious or philosophic beliefs
disclose membership to political parties organizations, associations with religious, philosophic, political or trade union goals;
or data, which refer to the health, sexual life or the human genome.
NO PERSONAL DATA ARE COLLECTED AND NO USERS ARE REGISTERED WHO ARE UNDER THE AGE OF 13. IF YOU ARE UNDER 13 PLEASE DO NOT TRY TO REGISTER FOR OUR SERVICES AND DO NOT SEND US PERSONAL INFORMATION ABOUT YOU, INCLUDING BUT NOT LIMITED TO NAME, TELEPHONE, EMAIL. INOVENTO WILL DELETE ANY INFORMATION SENT BY OR REFERRING TO USERS WHO ARE KNOWN TO BE UNDER THE AGE OF 13.
IF YOU ARE UNDER THE AGE OF 16, IN ORDER TO REGISTER AS A USER OF THE WEBSITE AND IN ORDER TO USE THE SERVICES, YOU ARE REQUIRED TO DECLARE THAT YOUR PARENTS OR YOUR LEGAL GUARDIAN HAVE BECOME AWARE OF AND HAVE AGREED WITH THESE CONDITIONS.
5. WHO HAS ACCESS TO YOUR PERSONAL DATA?
Your personal data will not be transferred to third parties, unless
we have your express authorization for this;
the third parties in question provide support to us, under an agreement, for the supply of our products or the provision of our services to you;
it is required by law or when requested by a public authority;
when this is necessary to protect the rights, property and security of users of the Website or other public interest; or
in connection with the sale of a business, our company or its assets, subject to confidentiality obligations.
Inovento’s employees and consultants will have access to your personal data for the purposes of managing the Website, but are bound by a confidentiality obligation regarding the data to which they have access as part of the relevant IT base operations.
Inovento’s employees and consultants are duly informed of the importance of the compliance with such confidentiality legal duty and are liable for the compliance with that obligation.
When we request your consent, we will identify our affiliates and partners and the purposes of each transfer and sharing.
In addition, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. YOUR RIGHTS
Under the legislation in force, you are entitled to object, at any time and free of charge, to the processing of your personal data, by sending us a written request or by notifying us on the following email address: firstname.lastname@example.org
You are entitled to be informed every time before your personal data is transferred for the first time to third parties for the purposes of direct marketing, or when they are used on behalf of third parties. You are also entitled to object to this transfer or use, at any time and free of charge.
You are entitled to receive access upon notification to the personal data we store about you in a structured, commonly used and machine-readable format, by sending us a written request or by notifying us on the following email address: email@example.com
You are entitled to request the portability of your personal data to another data controller by sending us a written request or by notifying us on the following email address: firstname.lastname@example.org
If any of the data we have about you is incorrect or inaccurate, you may correct it by changing the information on your profile, by sending us a written request or by notifying us on the following email address: email@example.com
You are also entitled to request the complete erasure of your personal data by sending us a written request or by notifying us on the following email address: firstname.lastname@example.org
You may also request a restriction on the processing of your personal data with regard to specific actions on collection, processing or transferring by sending us a written request or by notifying us on the following email address: email@example.com
You are also entitled to request that third parties are notified about the rectification, erasure or restriction on the processing of your data so that these third parties comply with the respective request made by you.
In addition, you are entitled to file a complaint with the controlling authority which in Bulgaria, is the Commission for personal data protection (CPDP) with address: 1592 Sofia, 2 “Tsvetan Lazarov” Blvd.
7. PERSONAL DATA SHARING
The personal information, which is disclosed and shared by users on the Website, the social networks and other platforms upon using the Services, will be considered entirely provided at your own discretion and with your consent.
INOVENTO shall not be liable for the way personal data is shared by users on the Website, the social networks and other platforms through exchange of profiles, on a notice board, forums, blogs and in any other way is used, transferred, shared, exchanged and disclosed to third parties.
8. USER IDENTIFICATION
When you visit the Website and/or use our Services, you are identified as a User through your user registration (account) or through your IP address, which is a sequence of four numbers and designates the Internet address from which you access. Your IP address makes a reference to your Internet provider and may be traced by everyone who enters this address and make a search on the Internet.
As a registered user you will have constant access to your personal data at any time and may check what kind of data are stored about you, edit them, change or delete these data at your discretion.
9. PERSONAL DATA STORAGE
The data we collect about you will be stored on servers located within United States.
INOVENTO shall store the personal data provided by you for a specified period of time as it is necessary for achieving the purposes for which we collect and process the data, as specified herein, and in other cases established by law. If you do not log in for a period of 5 years, we will interpret this absence from the Website as disinterest in having an active registration and erase your personal data from our archives.
In case you want to delete your Account from the Website, all personal data that is stored about you, will be erased without delay.
By exception, we are entitled to further retention of the personal data where it is necessary, for exercising the right of freedom of expression and information, for compliance with a legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority vested in us in our capacity of Controller, on the grounds of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defence of legal claims.
We shall render due care to keep your data up-to-date according to and within the data provided by you on a free and voluntary basis and shall comply with your wishes and preferences. Provided that any changes occur in your data (for example a change in your email or any other contact detail) you should inform us about such changes so that we are able to keep the information up-to-date and correct.
The user shall be liable for the provided contact details and other data, which are untrue, false or refer to third persons (in all cases when such third persons haven't given their consent about that), as well as for any unlawful or malicious use of personal data and information.
10. OUR POLICY ON LOG FILES DATA
When you visit a website, your browser will send many and various data to the web server. Most of the web servers maintain logs users’ access. These logs contain data, which may be used for developing the overall picture about the popularity of the sites, the links from other sites and for the different browsers used by the users. INOVENTO will use the information from these logs to prepare statistics for the visiting of the website. Unprocessed data shall not be publicly disclosed and shall be regularly destroyed.
Our policy for provision of data collected in the server logs or accessible through the databases for the website administrators, the social networks and other platforms, contemplates data disclosure in the following cases:
Upon receipt of a court ruling, subpoena or another mandatory order by the judicial authorities.
In case of request in writing by a concerned user or upon receipt of the permission of such user.
In case of investigation based on complaints for misuses.
When data disclosure is required in order to solve technical problems.
If a user vandalizes the content of the Website or other platforms through which the Services are available , demonstrates constant malicious conduct or performs other malicious and unlawful actions, the data about his/her identity may be disclosed in order to enable the tracking of the IP-registers or submit complaints to the relevant providers of Internet services.
When there is a reasonable need to protect the rights, the property or the security of other users of the Services or other defendable public interest.
We shall use your e-mail address to send you an e-mail confirming your registration and a welcome e-mail. We shall also use your e-mail address to communicate with you regarding any services you may engage from us.
We would like to send you e-mails and/or text messages with information about our services, news about our activities, and any promotions or offers we are launching.
If you prefer not to be sent these e-mails and/or text messages, you may opt-out from receiving such notification at any time by:
not ticking the “opt-in” box before submitting the data in your registration form;
withdrawing your consent through the functionalities of the Website; or
contacting us at any time at firstname.lastname@example.org, informing us that you do not wish to be contacted.
12. TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES
Being a personal data controller, INOVENTO shall take all required technical and organizational measures in order to protect the data from accidental or illegal destruction or from accidental loss, from unauthorized access, amendment or distribution, as well as other illegal forms of processing.
Measures are consistent with the modern technological achievements and ensure level of protection, which corresponds to the risks associated with the processing and the type of the data, which must be protected.
All the information we receive from you will be stored on secure servers and we will implement technical and organizational measures that are suitable and necessary for your personal data to be protected with an appropriate level of security that will guarantee, in particular, the confidentiality and integrity of the data and prevent the destruction, the accidental or unlawful loss or changes, or the unauthorized disclosure or access of data.
In cases where we have supplied an access code to the Website, you acknowledge and accept that it is your responsibility to keep this code secret and confidential. We will never ask you to share this code with other people.
Notwithstanding the measures implemented to protect your data, you should be aware that the transfer of data through the Internet or other open networks is never completely secure and there is the risk that your data will be seen and used by unauthorised third parties.
INOVENTO does not give any guarantees against unauthorized access to any personal information or a part thereof.
13. CONTACT US
For additional information, complaints or requests for exercising of your legal rights, you can contact us at:
This policy enters into effect on May 25th, 2018 and is in compliance with the requirements of Regulation (EU) 2016/679 of the European parliament and 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 (General Data Protection Regulation).