ISKRA (BVI) Corp. (the “ISKRA”) complies with applicable laws for the protection of your privacy in the jurisdiction it actively engages in the business by offering ISKRA Services through ISKRA Platform.
1. Definitions
The “Personal Data” means any information that can either identify you as an individual or that
can be connected to you indirectly by linking it to Personal Identification Information. ISKRA also
processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage
patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the
identification of the customers to which it relates. ISKRA may share anonymous data, aggregated or not, with
third parties.
2. Why does ISKRA collect Personal Data
ISKRA collects and processes Personal Data for the following purposes:
a) Necessary for the performance of the services, contents and agreements;
b) Necessary for compliance with legal obligations;
c) Necessary for the purposes related to a legitimate third party; or
d) where you have given consent to it.
3. Which Personal Data does ISKRA collect
3.1. Personal Identification Data
First and last name, e-mail and mailing addresses, User ID, date of birth, government issued identification,
and User ID, password, discord data, wallet, and game related data.
3.2. Transaction Data
In order to make a transaction on the service of ISKRA (e.g. to purchase Subscriptions for Content and
Services or to fund your ISKRA Platform Wallet), you may need to provide payment data to ISKRA to enable the
transaction. If you pay by credit card, you need to provide typical credit card information (name, address,
credit card number, expiration date and security code) to ISKRA, which ISKRA will process and transmit to
the payment service provider of your choice to enable the transaction and perform anti-fraud checks.
Likewise, ISKRA will receive data from your payment service provider for the same reasons.
3.3. Other Data You Explicitly Submit
ISKRA will collect and process Personal Data whenever you explicitly provide it to us or send it as part of
communication with others on ISKRA Platform, e.g. in ISKRA Platform Community Forums, chats, or when you
provide feedback or other user generated content. This data includes:
Information that you post, comment or follow in any of the Content and Services;
Information sent through chat;
Information you provide when you request information or support from us or purchase Content and Services
from us, including information necessary to process your orders with the relevant payment merchant or, in
case of physical goods, shipping providers;
Information you provide to us when participating in competitions, contests and tournaments or responding to
surveys, e.g. your contact details.
3.4. Your Use of the ISKRA Platform Client and ISKRA websites
ISKRA will collect a variety of information through your general interaction with the websites, Content and
Services offered by ISKRA Platform. Personal Data that ISKRA will collect may include, but is not limited
to, browser and device information, data collected through automated electronic interactions and application
usage data. Likewise, ISKRA will track your process across ISKRA websites and applications to verify that
you are not a bot and to optimize the services.
3.5. Your Use of Games and other Subscriptions
In order to provide you with services, ISKRA needs to collect, store and use various information about your
activity in the Content and Services (your ISKRA Platform ID, game statistics including your games'
preferences, progress in the games, playtime, as well as information about the device you are using,
including what operating system you are using, device settings, unique device identifiers, and crash
data).
3.6. Cookies
ISKRA will use “cookies“, which are text files placed on your computer, and similar technologies
to help ISKRA analyze how users use ISKRA services, as well as to improve the services ISKRA is offering, to
improve marketing, analytics or website functionality. The use of cookies is standard on the internet.
Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours.
You may adjust your browser settings to prevent the reception of cookies, or to provide notification
whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on
your browser. When you visit any of ISKRA services, servers will log your IP address, which is a number that
is automatically assigned to the network your computer is part of.
3.7. Information Required to Detect Violations
ISKRA will collect certain data that is required for detection, investigation and prevention of fraud,
cheating and other violations of the Terms and Conditions and applicable laws. This data is used only for
the purposes of detection, investigation, prevention and, where applicable, and stored only for the minimum
amount of time needed for this purpose. If the data indicates that a Violation has occurred, ISKRA will
further store the data for the establishment, exercise or defense of legal claims during the applicable
statute of limitations or until a legal case related to it has been resolved.
4. How will ISKRA use your data
4.1. ISKRA will not process personal data except with the express consent of the data subject
(being the natural person, whether living or deceased, whose data is being processed) or where it is
necessary for certain specified reasons, such as the performance of a contract to which the data subject is
a party.
4.2. ISKRA will collect your data so that ISKRA can:
Process your order and manage your account; or
Email you with special offers on other products and services ISKRA think you might like.
4.3. If you agree, ISKRA will share your data with ISKRA’s partner companies so that they may offer
you their products and services.
[Other game production companies]
ISKRA will share your data with ISKRA’s third party service providers that provide customer support
services in connection with goods, Content and Services distributed via ISKRA Platform. Your Personal Data
will be used in accordance with this Privacy Policy and only as far as necessary for performing customer
support services.
In accordance with internet standards, ISKRA may also share certain information (including your IP address
and the identification of ISKRA Platform content you wish to access) with ISKRA’s third party network
providers that provide content delivery network services and game server services in connection with ISKRA
Platform. ISKRA’s content delivery network providers enable the delivery of digital content you have
requested.
When ISKRA processes your order, ISKRA may send your data to, and also use the resulting information from,
credit reference agencies to prevent fraudulent purchases.
4.4. Services of ISKRA’s website uses
4.4.1. ISKRA may request information (type of information includes given name, family name, crypto wallet
address, email address, date of birth, nationality, government identification number (Identification
Card/Passport/Driver License), photo of your face (selfie) and Purpose of transaction, Origin of fund) from
you to KYC/AML purpose. ISKRA perform KYC/AML through Shufti Pro and the information collected is not
processed by ISKRA. Only once you consent to the process, they start verifying your identity.
4.4.2. Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google
Analytics uses cookies to help the website operators analyze how visitors use the site. The information
generated by the cookie about the visitors' use of the website will generally be transmitted to and
stored by Google on servers in the United States.
4.4.3. reCAPTCHA, an API that help detect malicious traffic on website to protect your data by preventing
spamming and hacking by computer bots, your input data may be transmitted to reCATCHA. For more details you
can check out Google’s Privacy Policy.
4.5. ISKRA may allow you to link your ISKRA Platform User Account to an account offered by a third party. If
you consent to link the accounts, ISKRA may collect and combine information you allowed ISKRA to receive
from a third party with information of your ISKRA Platform User Account to the degree allowed by your
consent at the time. If the linking of the accounts requires the transmission of information about your
person from ISKRA to a third party, you will be informed about it before the linking takes place and you
will be given the opportunity to consent to the linking and the transmission of your information. The third
party's use of your information will be subject to the third party's privacy policy, which ISKRA
encourages you to review.
4.6 ISKRA may also transfer your Personal Data to service providers located in third countries/regions which
are considered as not providing the same level of data protection as the EU country in which you provided
your information. When ISKRA transfer your information, ISKRA will protect and provide adequate protection
for the transfer of your personal information to recipients in those countries / regions by entering into
data transfer agreements based either on the European Commission standards clauses with such data recipients
or any other valid transfer mechanisms that may be available in the future.
5. How Long ISKRA Stores Data
5.1. ISKRA will only store your information as long as necessary to fulfil the purposes for
which the information is collected and processed or to fulfil applicable law. After that your Personal Data
will be deleted, blocked or anonymized, as provided by applicable law.
5.2. In particular:
If you terminate your ISKRA Platform User Account, your Personal Data will be deleted except to the degree
legally required or other prevailing legitimate purposes dictate a longer storage.
In certain cases, Personal Data cannot be completely deleted in order to ensure the consistency of the
gameplay experience or the ISKRA Platform Community Market. For instance, matches you have played that
affect other players' matchmaking data and scores will not be deleted; rather, your connection to these
matches will be permanently anonymized.
Please note that ISKRA is required to retain your Personal Data under appricable law for a period of up to
five (5) years.
If you withdraw your consent on which a processing of your Personal Data, ISKRA will delete your Personal
Data without undue delay to the extent that the collection and processing of the Personal Data was based on
the withdrawn consent.
6. Your Rights
6.1. According to the applicable laws, you have the right to access your data that ISKRA holds
about you. If your requests affect the rights and freedoms of others, ISKRA would reserve the right to
charge a reasonable fee or refuse to act on the request.
6.2. If your data is inaccurate or incomplete, you can change the information you provided via the means
provided by ISKRA.
6.3. You have the right to delete your data if the reason why ISKRA could collect it does not exist anymore
or if there is another legal ground for its deletion. In order for you to request ISKRA to delete the data,
you must send an email to ISKRA specifying the specific item of data to be deleted and the desired time to
be deleted. As a result of deleting your ISKRA Platform User Account, you will lose access to ISKRA Platform
services, including the ISKRA Platform User Account, Subscriptions and game-related information linked to
the ISKRA Platform User Account and the possibility to access other services you are using the ISKRA
Platform User Account for.
6.4. If you object ISKRA will no longer process your data unless there are compelling and prevailing
legitimate grounds for the processing as described in applicable laws.
6.5 Right to restrict processing of your Personal Data
You have the right to obtain restriction of processing of your Personal Data under the conditions set out in
the applicable laws.
7. Children
The minimum age to create a ISKRA Platform User Account is 18. ISKRA will not knowingly collect
Personal Data from anyone under this age. Where certain countries apply a higher age of consent for the
collection of Personal Data, ISKRA requires parental consent before a ISKRA Platform User Account can be
created and Personal Data associated with it collected.
8. Contact Info
You can contact ISKRA's data protection officer at the address below.
[legal@iskra-bvi.com]
ISKRA (BVI) Corporation
Att. Data Protection officer
CCS Trustees Limited, Mandar House, 3rd Floor, Johnson’s Ghut, Tortola, British Virgin Islands, BVI.