By personal data, we refer to data that relates to you as an identified or identifiable person. The term “Personal Data” may include your name, your address, your telephone number, your e-mail address, your age, your gender, your game preferences for instance. Anonymous information, which we are not in a position to relate to you, does not qualify as Personal Data.
We may collect personal data as well as other information when you use the following services:
– Our webSites, including www.prospect.lt and www.prospect-app.ru and any other Prospect Site on which this Policy is posted (the “Site“).
– Our application „Prospect“ available at Google Play (the „Application“)
In this Policy we refer to the Site, the Application together as the “Services“.
We respect your right to privacy and will only process Personal Data and other information you provide to us or we collect about you in accordance with applicable privacy and personal data protection laws.
Who we are: Alenos Ramanavos individuali veikla,
Sausio 13-osios g. 31, LT-04347, Vilnius, Lithuania
(“we“, “our” and “us“).
We are a controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding its Services.
CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)
The contact details of person responsible for data protection while using the Application:
GENERAL INFORMATION IN BRIEF
We process personal data only when necessary for the performance of a contract with you. Processing is necessary for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms for which require the protection of your Personal Data.
Our legitimate interests are to provide our Services in an effective, safe and harmless manner. We want to provide everyone with a fair and balanced experience when using our Services.
We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
PROCESSING INFORMATION BY THIRD PARTIES
We may share Personal Data with our affiliates, subsidiaries, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services. Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Those companies may be located outside of the European Economic Area. Read more in Section “How we share your information”.
We recognise that we have a special obligation to protect personal information obtained from children. We will not knowingly collect Personal Data from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law).
We keep most of your Personal Data gathered and processed for the purposes described in this Policy for as long as you continue to use our Services, e.g. you have an activated Account in our Application. We will delete your Personal Data after you request your Account deletion.
Information we may collect from you
In relation to your use of our Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g. through our Site’s, Application or technology).
INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, your use of certain Services is possible only if you provide required information, e.g. while creating an Account.
When setting up an Account, you may be asked to provide Personal Data, including but not limited to your name, your social network, your user account password and account profile picture, email address, physical address and/or geo-location. You may also choose to provide some other optional information about you.
We may obtain your Personal Data when you register for and use our other Services, e.g., chats, or when you provide feedback about our Services. This data includes:
– Information sent through the “in-app chat” functionality in the Application.
– Information you provide when you request information or support from us or purchase a product or service from us, including information necessary to process your orders with the relevant payment merchant which may include the amount of any transaction, but will not include your financial information which will only be submitted directly to the payment merchant under secure protocols.
– Information relating to your profiles on social networking Site in order to allow integration with such social networking Site.
When you communicate while using the Services or within any other service (e.g. live chat, instant message services), even “privately” to another person, you do so with the understanding that those communications go through our servers, can be monitored by us, you have no expectation of privacy in any of those communications and, accordingly, you expressly consent to monitoring of communications that you send and receive. Please note that any information or images that you post to a public, such as in-app album, in-app gallery, is available to all persons accessing that location. In addition, you should be aware that if you save into your in-appp account any publicly available information in the Application, such as images uploaded and published by other users, this information and/ori mages will be publicly available to other users.
Social Networks Data.
INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our Services. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information (“Other Information”). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If we combine Other Information with Personal Data, we will treat the combined information as Personal Data.
The cookies that are used on our Site fall into the categories described below. These descriptions can help you determine if and how you would like to interact with our Site and other online services.
App-Related Information, Device Information, Geo-Location
In order to provide you with efficient services, we need to collect, store and use various information about your activity in our Application. “App-Related Information” includes your in-app identifier, as well as what is usually referred to as “application statistics”. By application statistics we mean information about your Application preferences, progress in the Application, as well as information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. Precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location.
Information from publicly available online resources
We may use the information made publicly available, e.g. through YouTube, vk.com, Facebook, Instagram and Twitter, in order to find out your opinion about Application and Services, so that we could take them into account while improving our Services.
HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to fulfil the contract with you according to Article 6(1)(b) of the GDPR. As a user, we will use your Personal Data, unless otherwise prohibited by law, for the following purposes:
- to provide you with the Services you request;
- to communicate with you about your Account or transactions with us and send you information about features on our Site or changes to our policies;
- to provide support including, but not limited to, product updates and fixes and other similar communications.
HOW WE SHARE YOUR INFORMATION
For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data with the following categories of third parties:
- Data storage partners: we store some of your information using third-party data storage services, e.g. Google Cloud, serveriai.lt.
- Publicly available information: our Site may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums, please use our Account Management tool to request its removal. If we may not be able to remove your personal information promptly, we will let you know about the reasons.
- Sharing anonymous information. We also may share anonymous information, i.e. information which does not directly or indirectly disclose your identity, and aggregated information (meaning information about groups and categories of users, including game statistics and behaviour, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the webSite of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
- We take reasonable precautions to prevent the loss, misuse or alteration of your personal data. Our employees, contractors and agents may be given access to your personal data which we collect, but their use shall be limited to the performance of their duties in relation to facilitating your use of the Services. Our employees, contractors and agents who have access to your personal data are required to keep that data confidential and are not permitted to use it for any purposes other than those listed above or to deal with requests which you submit to us.
- We have implemented all reasonable technical, administrative and physical security measures to protect the security of your data.
Third party Site
WE CAN CHANGE THIS POLICY
We may change this Policy from time to time for various reasons, such as legal and regulatory changes, changes in industry practices and technological developments that need to be reflected.