Privacy Policy of the HERO WARS project (the “Project”)
(Revised as of April 12, 2019)

Please review our Privacy Policy (hereinafter referred to as the “Policy”) to understand what type of data, for what purposes and in which ways we can process. The content of the updated Policy is made as clear as possible. If you have any questions or suggestions regarding our Policy, please send us an e-mail to: privacy@nextersglobal.com.

By accepting this Policy, you expressly agree to the provision, processing and storage of Data about you, subject to the scope and on terms specified in the Policy. By submitting your Data to us, you consent to storage, processing, transfer (including cross-border transfer, if required by the Services). By accepting this Policy, you accept the Terms of Service

By accepting this Policy you acknowledge and agree that you have reached the age allowing you to enter into such binding agreement in the country of your residence or domicile, or that you have your parent or legal guardian’s permission (if required by applicable law).

PROCESSED DATA

Depending on the type of platform and type of device on which you use the Project, we may process a different amount of information about you, which may also include your personal data, unless otherwise specified in this Policy. Upon such processing, we always proceed with respect to the principle of the minimum necessary information to be used and provide you with the highest quality Services as well as comply with generally accepted industry standards for the protection of the data provided to us (hereinafter referred to as the “Data”), both during transmission and immediately after they are received. However, no method of data transmission or storage over Internet provides a complete protection.

By the “Data”, we also refer to information that relates to you as an individual who is identified or is subject to identification. All information of your activity in the Project and (or) Service processed by us where it is necessary for providing access to the Project and (or) Services, is hereinafter referred to as the "Account". Subject to the provisions of this Policy, the Data may include but not limited to the following: your full name, your address, your telephone number, your e-mail address, your age, your gender, your intra-project behavior.

You can get a list of processed Data here: privacy@nextersglobal.com.

In order to provide the Project and (or) Services, we may transfer Data to contractors or agents acting in our interests. Such entities may be located in the European Economic Area or in those countries that provide an adequate level of personal data protection, as defined by the Regulations. We may transfer anonymous information, which does not allow us to identify you as an individual, to contractors that may reside within the territory of countries that are not EEA members.

We keep the Data during the validity period of the Account and within thirty (30) days from your request to delete, except for the information necessary to comply with the requirements of applicable law (e.g. tax and accounting laws) as well as anonymous information. We do not control the Data published by yourself, copied by other users as well as the Data published in the Project’s chat systems or on thematic groups and forums. We are committed to respect your rights and legitimate interests and any request for processing the Data will be considered. We may store your depersonalized account within the Project after deleting your Data where it is used in interaction with other users.

COOKIES

This type of information is a text file that helps to remember information about you. The Data shall not include any anonymous information that we are unable to relate to you. Such information may include Internet protocol (IP) addresses, the browser type, Internet service providers (ISP), referring/exit pages, operating systems, date/time stamps, and clickstream data. However, this information does not identify a particular user. We do not combine such information with any personal data.

We use a third-party tracking service that uses cookies and similar technology to track non-personal or private information on users and mobile application taken together (where applicable).

We use this cookie information for the following purposes:

  • To improve the Project and (or) Service content and performance;
  • To analyze trends and estimate our audience size and usage pattern;
  • To administer the web sites and speed up your searches;
  • To enable log in and authentication when you log onto our web sites;
  • To recognize you when you return to our web sites;
  • To deliver a better and more personalized services.

You may specify in your browser settings what kind of cookies your device should get and store. Our system will send cookies upon visiting the web sites, unless you have disabled this option in your browser settings. However, certain special features of the Project and (or) Service may not be available to you, if you do not accept our cookies policy.

We would like to provide you the Project access without collecting cookies, but, unfortunately, this is not always technically possible.

All major browsers offer advises and guidance for managing cookies to be available in your browser. To simplify the configuration of cookies please find links to cookies instructions in some browsers and advertising agents below:

Internet Explorer

https://support.microsoft.com/ru-ru/help/17442/windows-internet-explorer-delete-manage-cookies

Google Chrome

https://policies.google.com/technologies/cookies?hl=ru

Safari

https://www.apple.com/ru/legal/privacy/ru/cookies/

Yandex

https://yandex.com/support/metrica/general/opt-out.html

Facebook

https://www.facebook.com/help/499864970040521

VK.com

https://vk.com/privacy

OK.RU

https://ok.ru/res/privacypolicyRu.html

Please note, the above list of contractors is non-exhaustive and does not guarantee that we currently use all services of such companies. Since such list may be updated on occasional basis, you may request an up-to-date list by e-mail: privacy@nextersglobal.com.

To learn more about cookies, including which ones are on your computer, and how to manage or delete them, we can recommend you to visit: www.allaboutcookies.org.

Some functionality can use the Google Analytics service to track your activity. If you want to stop tracking by Google Analytics across all websites, please visit http://tools.google.com/dlpage/gaoptout.

LOCAL LEGISLATION

We provide you with access to international projects, and strive to comply with applicable local laws. Please note that our Services are provided "as is" and you should get to know with applicable laws. By continuing your use of the Project, you are warrant that your use of the Project is not contrary to the applicable law and Terms of Service.

We use technical means to determine the region where you use the Project and (or) Service (without accuracy, which means that we cannot determine the place of the user and identify him) in order to determine the applicable legislation. We do not collect, store or process personal Data of Russian citizens in accordance with applicable Russian laws. You may provide Data only for the purposes of the Terms of Service.

Please pay your attention to the fact that there is a number of countries where any use of VPN-services and similar software products in order to disguise your region of residence, is not allowed. WE INFORM YOU THAT BEFORE USING THE PROJECT AND (OR) SERVICE, IT IS IN YOUR INTERESTS TO READ YOUR LOCAL PERSONAL DATA LAWS.

REASONS FOR DATA PROCESSING

We process your Data only when necessary to provide access to the Project and (or) Services, while taking reasonable security measures to protect your Data from loss, misuse and unauthorized access, disclosure, modification or destruction.

With respect to the users covered by the General Data Protection Regulation (EU) 2016/679 (hereinafter – the “GDPR”), we use the Data collected through the Project and (or) Services for the purposes of our legitimate interests in accordance with Article 6(1)(f) of the GDPR as well as for the purposes stipulated in the Terms of Service and this Policy. E.g., we may use information we collect -

  • to provide our Services or information you request as well as to process and complete any transactions;
  • to respond to your submissions, questions, comments, requests and complaints as well as to provide customer service;
  • to monitor and analyze the Project’s use and trends or to personalize and improve the Project or user experience on our web sites, such as providing ads, Content or features that match their profiles or interests as well as to increase the Project’s functionality and user friendliness;
  • to provide gifts and rewards that you may have to win in the Project etc.;
  • to send you confirmations, updates, security alerts as well as support and administrative messages and otherwise
  • to facilitate your use of and our administration and operation of our web sites; and
  • any other purpose for which the information is collected.

Data is collected when you provide it within the Project and (or) Service. Indirect collection shall be allowed only on anonymous basis.

DATA PROTECTION

The project implemented reliable means of protection to ensure the security of your data. We do everything possible for your safety when using the Project and are constantly improving our information protection methods. As some means of protecting information from unauthorized access, alteration, disclosure or destruction, we use the following methods:

- data encryption during storage and transmission;

- we carry out two-stage user authentication when requesting an action with the Data;

- we improve the techniques and methods of collecting, storing and processing the Data;

- access to the Data, in encrypted and impersonal form, have only authorized employees, consultants or interested groups of people who need access to this information to perform their duties;

- all persons having access to the Data are briefed on working with data, their knowledge and skills are systematically being checked.

In spite of all measures taken by us, your careful attitude to the Account and access to it has a great importance in the safety of your the Data. To prevent unauthorized access to your Data and Account, we strongly recommend you not to share access to the account to any third parties and to comply with the rules of the project and use of the Services. In case of your violation of the Terms of Use of the Services, we will not be able to guarantee the security of your Data.

DATA MANAGEMENT

You have all the technical capabilities to determine how the Data shall be used. In order to apply regarding the usage of the Data of EU citizens and other persons covered by the GDPR, you should go to the "Settings" section, then go to the "Support" section and fill out the application form. In addition, by sending a request to an email. privacy@nextersglobal.com you may :

- withdraw your consent given in accordance with Article 6(1)(a) of the GDPR in full or in part;

- access to your Data received by us, i.e. you may request the information on the Data’s storage and access as well as a copy of such Data that will be provided to you within thirty (30) days from the date of your request;

We reserve the right to decline your request, if it affects the rights and freedoms of other persons or lacks any clear justification.

- require limitation of Data processing for the time required to verify the reliability of the information provided;

- change the Data;

You may discretionary determine the Data, which shall be associated with your Account.

- object to the processing of your Data;

If you believe that we have no legitimate reason for processing your Data, please contact us using the contacts provided below.

You may also file a complaint with the local supervisory authority:

- to implement your right to data portability where there is a technical capability to do so;

- to delete your Account and Data related therewith. If your Account is deleted, you will lose access to the Project and your Data will be permanently deleted within thirty (30) days from the date of your request.

Upon the formation of the request and its execution, we verify the user and may request additional actions or clarifications from you in order to confirm the ownership of the Data.

These measures are necessary for the security of the Data. We reserve the right to decline your request, if it affects the rights and freedoms of other persons or lacks any clear justification. Requests shall be to be executed within thirty (30) days, unless additional measures are required to ensure the security of your data.

In case you have lost access to the Project and do not have the technical ability to perform actions to confirm the ownership of the Data, you can send a letter to the address:

107 Faneromenis Avenue

6031, Larnaca, Cyprus

Recipient: NEXTERS GLOBAL LIMITED

The letter shall provide adequate information that allows us to reasonably determine that the account in question is actually belonging to you.

The controller for the purposes of the GDPR and other applicable data protection or data privacy laws of the EU Member States as well as other data protection requirements in respect of the Project is:

NEXTERS GLOBAL LIMITED
107 Faneromenis Avenue
6031, Larnaca, Cyprus
Email: info@nextersglobal.com

FULL NAME AND CONTACT DETAILS OF THE AUTHORIZED DATA PROTECTION MANAGER FROM NEXTERS GLOBAL LIMITED:

NEXTERS GLOBAL User Data Protection Manager:

Personal Data Specialist
107 Faneromenis Avenue
6031, Larnaca, Cyprus

Email: privacy@nextersglobal.com

FINAL PROVISIONS

We reserve the right to modify this Policy at any time, so please review it on a periodic basis.

This Policy is made in English language. We can provide you with a translation in French, German, Italian, Spanish and Portuguese languages. In case of any inconsistency or discrepancies between a non-English translation of this Policy and the English version, the English version shall prevail.

FAITHFULLY YOURS,
NEXTERS GLOBAL LIMITED