SUPPLEMENTAL PRIVACY NOTICE FOR PROMOTIONS
Last updated: 15 October 2024This Supplemental Privacy Notice for Promotions ("Privacy Notice") explains how X-FLOW LTD, a data controller with registered office at 8 Genethliou Mitella, 3036, Limassol, Cyprus, ("Company," "we," "us," "our") collects, uses, and protects personal data in the context of sweepstakes, contests, promotions, and similar activities (collectively, "Promotions"). This Notice is intended to supplement our general Privacy Policy which can be found at the link: https://xflowgames.com/privacy-policy.html (“Privacy Policy”). You should make sure to refer to both this Privacy Notice and the Privacy Policy to get all the information you need about how we process your Data when you participate in our Promotions. By participating in our Promotions, you acknowledge that you have read and understood this Privacy Notice.
A. WHAT DATA WE COLLECT
We may collect and process the following categories of personal data when you participate in Promotions:
- Identity Data: Including but not limited to your name, date of birth, likeliness, gender and tax number, as well as copies of your proof of identity and/or other eligibility documents.
- Contact Data: Including but not limited to your email address, telephone number, and mailing address, social media account.
- Participation Data: Including but not limited to responses, entries, and any other content you submit.
- Any other Data you voluntiraly provide to us.
B. WHY WE COLLECT AND USE YOUR DATA
We process your personal data for the following purposes and based on the following legal basis:
| Purposes | Legal Basis |
|---|---|
| Administration & Operation: To administer and manage Promotions, including notifying winners and delivering prizes. | Performance of a contract (Art. 6 para. 1 lit. b) GDPR): Processing is necessary for the performance of a contract to which you are a party (e.g., the terms and conditions of the Promotion). |
| Compliance: To comply with legal obligations, including verifying your eligibility to participate. | Legal Obligations (Art. 6 para. 1 lit. c) GDPR): Processing is necessary for compliance with legal obligations, such as tax regulations and fraud prevention. |
| Analytics & Improvement: To analyze participation for insights and improvement of our services and future Promotions. | Legitimate Interests (Art. 6 para. 1 lit. f) GDPR): For legitimate interests pursued by us or a third party, provided your interests and fundamental rights do not override those interests. |
C. HOW WE SHARE YOUR DATA
We may share your personal data with:
- Service Providers: Such as IT service providers and logistics partners who assist us in administering the Promotions.
- Legal Authorities: If required to comply with legal obligations or to protect our rights and properties.
D. OTHER PROVISIONS
Please refer to Privacy Policy to get more information about International Data Transfers, Your Rights, Security Safeguard and Data Retention.
E. CHANGES TO THIS NOTICE
We may update this Notice from time to time. Any changes will be posted on this page with an updated effective date.
F. CONTACT US
If you have any questions or concerns about this Privacy Notice or our data processing practices, please contact us at [email protected] or our DPO at [email protected].