Privacy Policy

Last updated August 14, 2023

This privacy notice (hereinafter referred to as the “Privacy Policy”) for the website at https://igropad.com/ (hereinafter referred to as the “Website”) owned by Aleksandr Butkov, residing on Bulevar Mihajla Pupina 10g, 11075 Belgrade, Serbia (hereinafter referred to as either “Company”, “We”, “Us”, or “Our”). The Privacy Policy describes how and why We might collect, store, use, transfer, and/or share (hereinafter referred to as “Process”) personal information provided by you as an individual, a company, or other legal entity (hereinafter referred to as either “You”, “Your”, or “User”) when You use Our services related to the Website (hereinafter referred to as the “Services”), such as when You do the following:

  • Visit, use, or navigate Our Website.
  • Participate in activities on the Website.
  • Register on the Website.
  • Contact Us and/or provide Us feedback on Our contact page.

Reading this Privacy Policy will help You understand Your privacy rights and choices. If You do not agree with Our Privacy Policy and its practices, please do not use Our Services. By using the Services, You agree that We may Process necessary information in accordance with this Privacy Policy.

Interpretation of definitions.

Some words in which the initial letter is capitalized have meanings defined at first usage in this Privacy Policy. Such definitions have the same meaning regardless of whether they appear singular or plural.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information provided by You.

The personal information that We collect depends on how You interact with Us and the Services, the choices You make, and the Services You use.

If You choose to register on the Services and this option is available, the personal information We collect includes the following:

  • Username
  • Password
  • Email address

If You choose to contact Us and/or provide Us feedback on Our contact page or via email, the personal information We collect includes the following (if the following is specified in the corresponding text fields):

  • Email address
  • Information included in Your text message

The provision of such data is not a statutory or contractual requirement, and You are not obliged to use this Services and provide related personal data.

Information automatically collected.

We automatically collect certain information when You visit, use, or navigate the Services. This information does not reveal Your specific identity but includes device and usage information, such as Your IP address (Internet Protocol address), browser and device characteristics, operating system, language preferences, referring URLs, device name, country, imprecise location, information about how and when You use Our Services, and other technical information. This information is primarily needed to maintain the security and operation of Our Services, and for Our internal analytics and reporting purposes. Such information We collect includes:

  • Information about device. We collect information about Your computer, phone, tablet, or other device You use to access the Services. Depending on the device used, this information includes IP address, device and application identification numbers, imprecise location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Imprecise location data. We collect information about Your device’s imprecise location, such as country, region, or town.
  • Log and usage data. Log and usage data is service-related, diagnostic, usage, and performance information Our servers automatically collect when You access or use Our Services and which We record in log files. Depending on how You interact with us, this log data includes Your IP address, device information, browser type, and settings and information about Your activity in the Services (such as the date/time stamps associated with Your usage, pages, and files viewed, searches, and other actions You take such as which features You use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

Do We collect or Process sensitive personal data?

We do not collect or Process sensitive personal data (such as trade-union membership).

Do We have solely automated decision-making?

We do not make any decisions based solely on automated processing, including profiling, which produce legal effects concerning You or similarly significantly affects You.

2. HOW DO WE COLLECT YOUR INFORMATION?

We collect personal information that You directly provide Us when You:

  • Visit, use, or navigate Our Website.
  • Participate in activities on the Website.
  • Register on the Website.
  • Contact Us and/or provide Us feedback on Our contact page or via email.

Like many businesses, We also collect information through cookies and similar technologies. You can find out more about this in the section “HOW DO WE USE COOKIES?” below.

3. HOW AND WHY DO WE PROCESS YOUR INFORMATION?

We Process Your personal information for a variety of reasons, depending on how You interact with Our Services, including the following purposes (i.e., “legitimate interests” under EU or UK data protection laws):

  • To provide and facilitate the delivery of Services to the User. We Process Your information to provide You with the requested Service and facilitate or improve such delivery in the future.
  • To analyze usage information and improve Our Services. We Process information about how You use Our Services to better understand how they are being used so We can improve them by that.
  • To prevent problems and protect Our Services. We Process Your information as part of Our efforts to keep Our Services safe and secure, including fraud monitoring and prevention.
  • To provide business transfer. We may Process Your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Our business to another company.
  • To respond to User inquiries and provide support to the User. We may Process Your information to respond to Your inquiries and solve any potential issues You might have with the requested service.
  • To provide account creation and authentication or otherwise manage User account. We may Process Your information so You can create and log in to Your account, as well as keep Your account in working order.
  • To enable the possibility of communications between users. We may Process Your information if You choose to use any of Our Services that allow communication with other users or participating in public activities (for example, by posting content to the Website).
  • To provide and improve marketing and promotional activities. We may Process Your information to better understand how to provide marketing and promotional campaigns that are most relevant to You.
  • To deliver personalized content or targeted advertising to the User. We may Process Your information to develop and display personalized content or targeted advertising. For more information about the targeted advertising, please see the section “Do We serve targeted advertising?” below.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We Process Your personal information only when it is necessary for some of Our purposes, described in the section “HOW AND WHY DO WE PROCESS YOUR INFORMATION?” above, and when We have a valid legal reason (i.e., legal basis) to do so under applicable law.

If You are located in the European Union (EU) or United Kingdom (UK), the following section applies to You.

The General Data Protection Regulation (GDPR) and UK GDPR require Us to explain the valid legal bases We rely on in order to Process Your personal information. As such, We primarily rely on the following legal bases to Process Your personal information:

  • Legitimate interests. We Process Your information when it is reasonably necessary to achieve Our legitimate interests and those interests do not outweigh Your interests and fundamental rights and freedoms. For example, We Process Your personal information when it is necessary for some of Our legitimate interests, described in the section “HOW AND WHY DO WE PROCESS YOUR INFORMATION?” above.
  • Consent. We may Process Your information if You have given Us permission (i.e., consent) to use Your personal information for a specific purpose. You can withdraw Your consent at any time. For more information, please see the section “HOW CAN YOU CONTROL COOKIES?” below.

Also, We may rely on the following legal bases to Process Your personal information:

  • Legal obligations. We may Process Your information when it is necessary for compliance with Our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend Our legal rights.

In legal terms, We are generally the “data controller” under European data protection laws of the personal information described in this Privacy Policy, since We determine the means and/or purposes of the data processing We perform.

If You are located in Canada, the following section applies to You.

We may Process Your information if You have given Us specific permission (i.e., express consent) to use Your personal information for a specific purpose, or in situations where Your permission can be inferred (i.e., implied consent). You can withdraw Your consent at any time.

In some exceptional cases, We may be legally permitted under applicable law to Process Your information without Your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the information is publicly available and is specified by the regulations

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share Your data with third-party vendors, service providers, contractors, or agents (hereinafter referred to as either “Third Parties”, “Third Party”, or “Third-Party”) who perform services for Us or on Our behalf and require access to such information to do that work. We have contracts or other applicable agreements with Our Third Parties, which are designed to help safeguard Your personal information. This means that they cannot do anything with Your personal information unless We have instructed them to do it. They will also not share Your personal information with any organization apart from us. They also commit to protect the data they hold on Our behalf and to retain it for the period We instruct. The Third Parties We share personal information with include the following (presented by categories):

For more information about their contacts, locations, and privacy policies, please follow the corresponding links in the list above.

We also may need to share Your personal information in the following situations:

  • To provide business transfer. We may share Your information with another company in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Our business to another company.
  • To enable the possibility of communications between users. We may share Your information with other users if You choose to use any of Our Services that allow communication with other users or participating in public activities (for example, by posting content to the Website).

Do We sell any personal data to Third Parties?

We do not sell any personal data to Third Parties.

6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Services may link to Third-Party websites, online Services, or mobile applications and/or contain advertisements from Third Parties that are not affiliated with Us and which may link to other websites, services, or applications. Accordingly, We do not make any guarantee regarding any such Third Parties, and We will not be liable for any loss or damage caused by the use of such Third-Party websites, services, or applications. The inclusion of a link towards a Third-Party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data You provide to any Third Parties. Information provided by You to Third Parties is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any Third Parties, including other websites, Services, or applications that may be linked to or from the Services. You should review the policies of such Third Parties and contact them directly to respond to Your questions.

7. HOW DO WE USE COOKIES?

This section explains how and why We use cookies and similar technologies and what these technologies are.

Your rights to control Our use of cookies described in the section “HOW CAN YOU CONTROL COOKIES?” below.

What are cookies?

Cookies are small data files that are placed on Your computer or mobile device when You visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, by the Company) are called “first-party cookies.” Cookies set by parties other than the website owner are called “Third-Party cookies.” Third-Party cookies enable Third-Party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these Third-Party cookies can recognize Your computer both when it visits the website in question and also when it visits certain other websites.

Why do We use cookies?

We use first-party and Third-Party cookies for several reasons. Some cookies are required for the proper functioning of Our Website, and We refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable Us to enhance the performance and functionality of Our Website. Third parties serve cookies through Our Website for advertising, analytics, and other purposes. This is described in more detail below.

What types of cookies do We use?

The categories of first-party and Third-Party cookies used on Our Website and the purposes they fulfill are described below:

  • Strictly necessary cookies: These cookies are necessary to provide You with essential Services, such as visiting, using, or navigating the Website.

  • Functionality and usability cookies: These cookies are used to improve the functionality of the Website or to make Our Services more comfortable to use. Without these cookies, certain non-essential functionality (like videos) may become unavailable.

  • Analytics and performance cookies: These cookies are used to help Us understand how Our Website is being used, how effective Our Services are, or to enhance the performance of the Website.

  • Advertising and targeting cookies: These cookies are used to make advertising messages more relevant to You. Also, they may perform functions like preventing the same ad from continuously reappearing or ensuring that ads are properly displayed.

Do We serve targeted advertising?

With your consent, Third Parties may use cookies on Your computer or mobile device to serve targeted advertising through Our Website. These companies may use cookies to collect information about Your visits to this and other websites in order to provide relevant advertisements about goods and services that You may be interested in. They may also use cookies to measure the effectiveness of advertisements. The information collected through this process does not enable Us or them to identify Your name, contact details, or other details that directly identify You unless You choose to provide these.

You can opt out of advertising cookies at any time by disabling them in the Cookie Consent Manager, which can be found by pressing this link. For more information about the Cookie Consent Manager, please see the section “HOW CAN YOU CONTROL COOKIES?” below.

8. HOW CAN YOU CONTROL COOKIES?

You have the right to decide whether to accept or reject cookies. Also, You have the right to withdraw Your consent at any time. You can exercise Your cookie rights by setting Your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows You to select which categories of cookies You accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide You with Services.

The Cookie Consent Manager can be found in the notification banner when You visit Our Website for the first time or by pressing this link. You may also set or amend Your web browser controls to accept or refuse cookies.

How can You control cookies on Your browser?

Most Web browsers are set to accept cookies by default. If You prefer, You can usually choose to set Your browser to remove or reject cookies. If You choose to reject cookies, certain functionality (like videos) may become unavailable. As the means by which You can remove or refuse cookies through Your web browser controls vary from browser to browser, for more information, please visit Your browser’s help menu or related web page.

9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our facilities where data is Processed (i.e., “servers”) are located in the United States. If You use Our Services from outside the United States, please be aware that Your information may be transferred internationally to be Processed in the United States by Our servers and servers of those Third Parties with whom We may share Your personal information. For more information about such Third Parties and their privacy policies, please see the section “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then We may rely on the existing adequacy decision by the European Commission, which means that the United States ensures an adequate level of protection and data can be transferred from the EEA or UK to that country without any further safeguards being necessary.

In any case, We will take all necessary measures to protect Your personal information in accordance with this Privacy Policy and applicable law (for example, by pseudonymization of data when possible).

10. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep (i.e., “retain”) Your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will keep Your personal information in most cases for no longer than 14 months after the last date of Your related activity, and in case You have chosen to create a user account previously, for no longer than the period of time You have had that account with Us, and only regarding information necessary for such Service.

When We have no ongoing legitimate business need to Process Your personal information, We will either delete or anonymize such information, or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible.

11. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information We Process (for example, by pseudonymization of data when possible). However, despite Our safeguards and efforts to secure Your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized Third Parties will not be able to defeat Our security and improperly collect, access, steal, or modify Your information. Although We will do Our best to protect Your personal information, transmission of personal information to and from Our Services is at Your own risk. You should only access the Services within a secure environment.

12. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from children under 18 years of age. By using the Services, You represent that You are at least 18 or that You are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If We learn that personal information from Users less than 18 years of age has been collected, We will take reasonable measures to promptly delete such data from Our records. If You become aware of any data We may have collected from children under age 18, please contact Us through Our contact page igropad.com/feedback or by email [email protected].

13. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), United States (U.S.), and Canada, You have certain rights under applicable data protection laws, including the following rights:

  • Of access – You have the right to request that We provide you with a copy of Your personal data.
  • To rectification – You have the right to request that We correct any information You believe is inaccurate. You also have the right to request that We complete the information You believe is incomplete.
  • To erasure – You have the right to request that We erase Your personal data under certain conditions.
  • To restrict processing – You have the right to request that We restrict the processing of Your personal data under certain conditions.
  • To object – You have the right to object to Our processing of Your personal data under certain conditions.
  • To data portability – You have the right to request that We transmit the data we have collected to another organization, or directly to You, under certain conditions.
  • To lodge a complaint with a supervisory authority – You have the right to complain to Your local data protection supervisory authority.
  • Not to be subject to a decision based solely on automated processing – You have the right not to be subject to a decision based solely on automated processing, which produces legal effects concerning You or similarly significantly affects You.
  • To non-discrimination for the exercise of Your privacy rights – You have the right not to be discriminated against for the exercise of Your privacy rights.
  • To limit the use and disclosure of sensitive personal information – You have the right to request that We limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the Services.
  • To be informed – You have the right to be informed about the collection and use of Your personal data, including the following information:
    • whether or not We collect and use Your personal information;
    • the purposes for which the collected personal information is used;
    • the categories of personal data that We collect;
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed;
    • the appropriate data transfer safeguards;
    • the envisaged period for which the personal data will be stored;
    • whether the provision of personal data is a statutory or contractual requirement;
    • the existence of automated decision-making, including profiling;
    • whether We sell or share personal information to Third Parties;
    • the specific pieces of personal information We collected about You.
    • the categories of personal information that We sold, shared, or disclosed for a business purpose;
    • the categories of Third Parties to whom the personal information was sold, shared, or disclosed for a business purpose;
    • the business or commercial purpose for collecting, sharing, or selling personal information;

If You wish to exercise these rights or have any questions or concerns about Our Privacy Policy, You may contact Us through Our contact page igropad.com/feedback or by email [email protected].

Please note that we may ask You to verify Your identity before responding to certain types of requests. We will consider and act upon any request in accordance with applicable data protection laws.

You have the right to withdraw Your consent:

If We are relying on Your consent to Process Your personal information, which may be express and/or implied consent depending on the applicable law, You have the right to withdraw Your consent at any time. You can withdraw Your consent by using the Cookie Consent Manager, which can be found by pressing this link. For more information about the Cookie Consent Manager, please see the section “HOW CAN YOU CONTROL COOKIES?” above.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of Your personal information conducted in reliance on lawful processing grounds other than consent when applicable law allows.

You have the right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling that produce legal or similarly significant effects:

We do not sell any personal data to Third Parties. Also, We do not make any decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects. If you still wish to opt out of the processing of Your personal for such purposes, You may contact Us through Our contact page igropad.com/feedback or by email [email protected].

With your consent, Third Parties may use cookies on Your computer or mobile device to serve targeted advertising through Our Website. For more information about the targeted advertising, please see the section “Do We serve targeted advertising?” above.

You have the right to opt out of the processing of targeted advertising cookies at any time by disabling them in the Cookie Consent Manager, which can be found by pressing this link.

Also, You have the right to opt out of sharing Your personal information using cookies with Third Parties at any time. To do so, you can disable all but strictly necessary cookies in the Cookie Consent Manager, which can be found by pressing this link.

For more information about the Cookie Consent Manager, please see the section “HOW CAN YOU CONTROL COOKIES?” above.

You have the right to opt out of marketing and promotional communications:

We are not sending marketing and promotional communications (such as emails or SMS messages) at the moment. However, We may communicate with You for other non-marketing purposes (for example, to respond to service requests or to send You service-related messages necessary for the administration of Your account). If you believe we are sending marketing or promotional communications to You, and/or you wish to opt out of them, You may contact Us through Our contact page igropad.com/feedback or by email [email protected].

14. CONTROLS FOR DO-NOT-TRACK FEATURES

Some web browsers and mobile operating systems include a Do-Not-Track (“DNT”) setting You can activate to signal Your privacy preference not to have data about Your online browsing activities monitored and collected. At this moment, no uniform technology standard for implementing DNT signals has been finalized. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked online. If such a standard for online tracking is adopted in the future, You will be able to learn more about that practice in the updated version of this Privacy Policy.

For more information about currently available tracking control options, please see the section “HOW CAN YOU CONTROL COOKIES?” above.

15. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Policy from time to time (for example, to stay compliant with relevant laws). The updated (i.e., “revised”) version will be indicated by a changed date at the top of this Privacy Policy. The updated version will be effective as soon as it is accessible. If We make material changes to this Privacy Policy, We will notify You by prominently posting a notice of such changes on the Website.

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

In some regions, You have certain rights under applicable data protection laws, such as the right to request access to the personal information We collect from You, change that information, or delete it in some circumstances. For more information about Your privacy rights, please see the section “WHAT ARE YOUR PRIVACY RIGHTS?” above.

If You wish to exercise these rights or ask any questions about Our Privacy Policy, You may contact Us through Our contact page igropad.com/feedback or by email [email protected].

Please note that we may ask You to verify Your identity before responding to certain types of requests. We will consider and act upon any request in accordance with applicable data protection laws.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If You have any questions or concerns about Our Privacy Policy, You may contact Us through Our contact page igropad.com/feedback or by email [email protected].