Privacy Policy

Vasin Maxim Vyacheslavovich (hereinafter the «Operator» or «Controller») publishes this Privacy Policy (hereinafter the «Policy») in respect of data subjects (hereinafter the «User») using the service located at wargm.com (hereinafter the «Site» or «Service»). Through the Service, the Operator provides access to a gaming online community, including a game catalogue, a ranking and monitoring of game servers, as well as the possibility of purchasing the Operator's services and the services of other users.

1. General Provisions

This Policy contains information on how the Operator collects, processes and discloses personal information about Users of the Site.
For the purposes of this Policy, Users means natural persons using the Site, including those registering and authorising, purchasing the Operator's services, posting offers of their own services or sending enquiries through the Site.
he processing of personal data is carried out by the Operator in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, «GDPR»), to the extent applicable, and with applicable data protection laws at the Operator's location and in the regions to which the Service is oriented.
Terms not defined in this Policy are used in the meanings established by the Terms of Service and other documents posted on the Site, as well as by applicable law.

2. Acceptance of the Privacy Policy

Before using the Site, the User should carefully review the conditions set out in the Policy. By using the Site, including by registering, authorising or sending an enquiry, the User confirms their understanding of the conditions set out in this Policy.
If the User does not agree with any conditions of this Policy, they must refrain from using the Site. Use of the Site without agreement with the conditions of this Policy is not permitted.
If, under the law applicable to the User, they are not entitled to independently enter into transactions or provide consent to the processing of personal data, use of the Site is permitted only with the consent of their legal representative. The Service is not directed to children under the age of 13 (or under 16 within the EU/EEA), and the Operator does not knowingly collect personal data from such minors without appropriate consent of a parent or legal representative. If the Operator becomes aware that personal data of such a minor has been collected without the required authorisation, such data will be deleted without undue delay.

3. Scope of Personal Information Collected

When using the Site, the User provides the Operator with the following personal information transferred by them upon registration, authorisation, use of the Service or contact with the Operator:

nickname (the User's name on the Site);
e-mail address;
contact telephone number - where indicated by the User;
data provided by third-party services upon authorisation through them (including the identifier and publicly available profile information) - where the User uses such authorisation;
information on the Balance, operations, purchased and rendered services;
payment data necessary for the transfer of funds due to the User (including bank card details for withdrawal) - for Users receiving payments;
other information voluntarily communicated by the User upon contact with the Operator, including the content of the enquiry.

The details of the bank card used to top up the Balance are not requested or stored by the Operator; the entry and processing of such details are carried out on the side of the bank and the engaged payment provider.
The Operator may additionally collect and process the following information about the User automatically:

data on the User's device and its interaction with the Site, including IP address, operating system version, browser type and version;
information on the User's actions on the Site, the date and time of visiting the Site;
information automatically obtained upon access to the Site by means of cookies.

The Operator uses cookies and similar technologies. Depending on their purpose, cookies are divided into the following categories:

strictly necessary cookies - required for the basic operation of the Site (including authorisation, security and session maintenance); such cookies are used without separate consent, as they are necessary for the provision of the Service;
functional cookies - used to remember the User's settings and preferences;
analytics cookies - used to assess and improve the operation of the Site and to analyse statistics of its use;
marketing cookies - used to display relevant advertising and information materials.

Cookies that are not strictly necessary for the operation of the Site (in particular functional, analytics and marketing cookies) are used on the basis of the User's consent, obtained where required by applicable law by means of a cookie banner or other interface element of the Site. The User may grant, refuse or withdraw such consent at any time, and may also refuse the processing of cookies by changing the settings of the browser used. Disabling cookies may result in the unavailability of certain functions of the Site.
The Operator may use web analytics services to assess and improve the operation of the Site. The processing of data by such services is carried out in accordance with their terms of use and, where required, on the basis of the User's consent.
The Operator does not process special categories of personal data (concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life) or biometric data. The User should not communicate such data to the Operator.

4. Legal Bases for Processing

The Operator processes personal data on the following legal bases:

performance of a contract to which the User is a party, or steps taken at the User's request prior to entering into a contract (provision of access to the Service and its services);
the Operator's legitimate interests (ensuring the security of the Service, preventing fraud, improving the operation of the Site), where such interests are not overridden by the interests or fundamental rights of the User;
the User's consent (in particular for advertising and information mailings, and for the processing of cookies not strictly necessary for the operation of the Site);
compliance with the legal obligations of the Operator.

Where processing is based on the User's consent, the User may withdraw such consent at any time; the withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Where the User's consent is required (in particular for advertising and information mailings and for cookies that are not strictly necessary), such consent is obtained through separate interface elements of the Site (including tick boxes and cookie banners) by an affirmative action of the User, and is not a pre-condition of registration or use of the Service, except where the relevant processing is necessary for the provision of a service requested by the User. The Operator records the fact and date of obtaining consent and retains such records for the purpose of confirming that consent was obtained.

5. Purposes of Processing Personal Information

The Operator processes the User's personal information for the following purposes:

providing access to the Service, registration and identification of the User, maintaining their Account and Personal Cabinet;
providing the User with the Operator's services and ensuring the functioning of the Service;
ensuring the conclusion and performance of transactions between users in respect of which the Operator acts as an agent;
carrying out settlements, accepting payment, accruing and recording Accounting Units, and paying funds due to the User;
issuing and sending payment and other documents in the cases provided for by applicable law;
reviewing and processing User enquiries, maintaining feedback;
ensuring the security of the Service, preventing fraudulent and other unlawful actions;
reviewing claims and resolving disputes;
improving the operation of the Site and analysing statistics of its use;
keeping records and reporting, fulfilling the obligations imposed on the Operator by applicable law.

The sending to the User of advertising and information materials (direct marketing) about the Operator's services, promotions, discounts, special offers and Service events is carried out on the basis of the User's consent, where such consent is required by applicable law. Consent is given by the User through a separate interface element of the Site (a tick box) and is voluntary; it is not a condition of registration, use of the Service or purchase of services.

For the purposes of direct marketing, the Operator processes the User's nickname, e-mail address, contact telephone number and identifiers in third-party services (including messengers) - where indicated by the User.
Advertising and information materials may be sent by e-mail, by means of notifications in the Personal Cabinet and other functionality of the Service, by means of messengers and third-party services, and by messages to the mobile telephone number - where the User has provided the relevant data.
The User may at any time refuse to receive advertising and information materials and withdraw the corresponding consent by following the «Unsubscribe» link in the message received, by changing the relevant settings in the Personal Cabinet, or by contacting the Operator at the e-mail address specified in Section 12 of this Policy. The refusal of marketing materials does not affect the User's use of the Service or the sending of service notifications connected with the functioning of the Service and the performance of obligations towards the User (including notifications of operations, the status of services and withdrawal requests).
The sending of advertising and information materials may be carried out both by the Operator itself and by third-party mailing services engaged by the Operator. When engaging such services, the Operator ensures their compliance with the requirements of applicable data protection law.

6. Principles of Processing Personal Information

In processing Users' personal information, the Operator adheres to the following principles:
Lawfulness, fairness and transparency. personal data is processed lawfully, fairly and transparently; information on the purposes, methods and scope of processing is set out accessibly.
Purpose limitation. personal data is collected and used solely for the purposes declared in this Policy.
Data minimisation. the Operator does not collect personal information in a volume greater than necessary for the purposes specified in this Policy.
Accuracy. personal information that is inaccurate is deleted or corrected at the User's request.
Storage limitation. personal data is stored no longer than necessary for the purposes of its processing.
Integrity and confidentiality. the Operator ensures the protection of personal data against unauthorised or unlawful processing, destruction, alteration and damage.

7. Disclosure of Personal Information to Third Parties

The Operator does not sell or trade Users' personal data.
The Operator may transfer (grant access to) the User's personal data to third parties to the extent necessary to achieve the purposes of processing, in the following cases:

to banks, payment providers and other organisations ensuring the acceptance of payment and the transfer of funds - for the purposes of settlements and payments;
to tax and other competent authorities - in accordance with applicable law;
to persons carrying out, on the Operator's instructions, technical support, hosting and support of the functioning of the Service, as well as the Operator's accounting and reporting - to the extent necessary to provide the relevant services;
to public authorities and other persons - in the cases provided for by applicable law.

When transferring personal data to persons processing it on the Operator's instructions (processors), the Operator ensures compliance by such persons with the requirements of applicable data protection law, including by concluding the necessary data processing agreements.
Upon the User's authorisation through third-party services, the exchange of information between the Operator and such services is carried out to the extent determined by the settings of the relevant third-party service and the User's consent. The conditions of data processing by third-party services are governed by their own documents.
The Site may contain links to other internet resources. The Operator is not liable for the content of such resources or for their processing of the User's personal information.

8. Cross-Border Transfers

Where the Operator transfers personal data to a jurisdiction other than the jurisdiction of the User, such transfer is carried out subject to appropriate safeguards required by applicable law, including, where applicable under the GDPR, on the basis of an adequacy decision, standard contractual clauses or other lawful transfer mechanisms.
The engagement of payment providers, hosting providers and other processors located in other jurisdictions is carried out subject to the conditions set out in clause 8.1 of this Policy.

9. Rights of the User

The User has the following rights in respect of their personal data, to the extent provided by applicable law (including, where applicable, the GDPR):

the right to be informed about the processing of their personal data and to access it;
the right to rectification of inaccurate or incomplete personal data;
the right to erasure of personal data («right to be forgotten»);
the right to restriction of processing and the right to object to processing;
the right to data portability;
the right to withdraw consent where processing is based on consent;
the right to lodge a complaint with the competent supervisory authority for the protection of data subjects' rights.

To exercise their rights, and to withdraw consent to the processing of personal data, the User may contact the Operator at the e-mail address specified in Section 12 of this Policy, or via the functionality of the Service.

10. Protection and Erasure of Personal Data

The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as against other unlawful actions in respect of personal data.
Personal data is processed from the moment of its receipt and throughout the period of the User's use of the Service, and after the cessation of use (including after deletion of the Account) - for the period established by applicable law, including for accounting and reporting records. Upon the achievement of the purposes of processing, the expiry of the storage period or the withdrawal by the User of consent (where retention of the personal data is no longer required), the Operator ceases processing and erases the personal data within a period not exceeding 30 (thirty) days, except in cases where their storage is required by applicable law. Where personal data (including payment and transaction data) is required to be retained for statutory tax, accounting or anti-money laundering (AML) purposes under applicable law, such data is securely archived and processed solely for those compliance purposes until the expiry of the statutory retention periods, after which it is deleted.

11. Amendment of the Privacy Policy

The Operator may at any time amend this Policy, without including in it provisions contrary to applicable law.
The new version of the Policy takes effect from the moment of its posting on the Site, unless otherwise provided by the new version of the Policy. The User is recommended to regularly review the current version of the Policy posted on the Site.

12. Details of the Operator

Operator: Vasin Maxim Vyacheslavovich
Registration No.: 20319957
Registered office: Yerevan, Armenia
Website: wargm.com