PRIVACY POLICY

Last amended: 3 September 2019

We are committed to protecting and respecting your privacy. We take your privacy seriously and will use your personal information (or data) to provide the services only after obtaining your consent for the collection and processing of your personal data on the terms specified below. We hope you will net all information to be assured your personal information is safe with us.

This Privacy Policy explains when where and why we collect personal information about people who use Fairspin, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal information as well as how we keep it secure.

Any questions or claims regarding this Policy and our services should be sent to support@fairspin.io

1. GENERAL INFORMATION

1.1. We believe that since you choose Fairspin for use you are familiar with the main focus of our services and business, and you have also of course not yourself acquainted with our Terms and Conditions. We will point at it once more for better understanding of the purposes your personal information is being collected and processed according to this Privacy Policy. The Controller of the personal data of the users on this website is the company Taktonum Group Ltd which is licensed and regulated by the Gaming Services Provider N.V. Holder of Master License #365/JAZ established in Curacao. The Processor of the personal data of the users on this website is the Company Fabeltra Ltd., company number HE399178 and registered office at Boumpoulinas, 1-3 Bouboulina building, 4th floor, flat/office 42, 1060, Nicosia.

1.2. Personal data subjects are visitors of this website and/or persons who use the functionality of this website (hereinafter referred to as "Users" or "You").
Fairspin and «the User» are together referred to as «Parties», and «the Party» when being mentioned separately.


1.3. This Privacy Policy constitutes the integral part of Terms and Conditions. All terms used in this Privacy Policy shall be understood and interpreted as set out in the Terms and Conditions.

1.4. We may change the Policy from time to time and indicate the date of the last amendments on the top in the “Last amended” field, so please check this page to ensure that you’re happy with any changes. The additional notifications on any amendments shall be sent to your email address. If within one week after the notification is sent you continue to use Fairspin, you will be considered as having accepted all the amendments made.

2. LEGAL BASIS FOR PROCESSING 

2.1. We comply with the principles established by the General Data Protection Regulation (Regulation (EU) 2016/679), namely, Personal Data:

2.2. Note that we may process your Personal Data not only on the basis of your consent, but also when one of the following applies:

2.3. In all cases, we will notify you about applied legal basis for processing and other relevant details, before we start process your personal data on the specific legal basis unless we are not able to do so in accordance with our obligations under any applicable legislation.

3. COLLECTION OF THE PERSONAL INFORMATION 


3.1. Personal information (or data) is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to the person that collects and processes such information to identify you as an individual. It can be your name, your identification number, your location data, or information related to your physical, physiological, genetic, mental, economic, cultural or social life. Processing of the information means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.

3.2. We may collect Personally Identifiable Information (PII) such as name, telephone number and email address. Also, we may collect Aggregate Information such as frequency of visits to website, IP address, site panes most frequently accessed, browser type, operating system type, your Internet service provider or mobile carrier. Aggregate information is non-personally identifiable /anonymous information about users of the Fairspin platform. Aggregate information is used in a collective manner and no single person can be identified by that compiled information.


3.3. When you access the website, or use our products or services we (or a service provider on our behalf) may collect certain analytical or statistical information to recognize you as our user; customize our website and advertising; measure promotional effectiveness and collect information about your computer or other access device to imitate risk, help prevent fraud, and promote trust and safety. For these purposes, we use third party services, including Google Tan Manager, yandex.metrika, chimpstatc, cdn.sendpulse.com, secure.adnxs.com, intercom and telegram-chat.

4. PURPOSES OF THE COLLECTION

As you can see there is not much personal information Fairspin collects from you. Nevertheless, all the information Fairspin collects from you is crucial for the operation of the Fairspin platform. Fairspin collects and uses the information to:

4.2. Disclosure of your Personal Data. Your Personal Data may be disclosed (transferred) by the Fairspin to any of our affiliated companies or any business partners (regardless of their territorial location) for the purposes described above in this Policy. We guarantee that such companies are aware of the correctness of personal data processing according to the General Data Protection Regulation (Regulation (EU) 2016/679), and comply with the provisions of this regulatory enactment.
We and the above-mentioned companies may from time to time involve third parties for the processing of Your personal data for the purposes indicated above, provided that such processing will be governed by contractual arrangements in the form prescribed by law. Your personal data may also be disclosed to the appropriate governmental, regulatory or executive body in case it is prescribed or permitted by law.


4.3. If Fairspin decides to change the purposes of processing specified above, we will inform you on such changes prior to use your personal information within the newly set purposes. The notification on such changes will be sent to your email.

5. PROCESSING OF THE PERSONAL INFORMATION 


5.1. In order to provide high-quality services within the Platform Fairspin hires people, enter the agreements with independent contractors as well as cooperates with other services providers, companies and organizations. For that reasons, some of your personal information can be passed to the persons mentioned. For example, Fairspin uses Sum Substance services ( htps://sumsub.com ) to verify your identity and/or address to provide you with the access to all the names available on the Platform. If this is done, the rules for processing and transfer of data set by the relevant services.


5.2. In order to achieve the Platform goals in a best way the Fairspin uses various technologies and services including the one provided and/or hosted in EU, US and other countries. Some of them guarantee very high level for the personal data protection, in some of them the level of protection is lower. By registering the TruePlay Wallet, and by using Fairspin you agree to such transfer and processing within the purposes set in Section 4 of this Privacy Policy.


5.3. In all cases we pass the information to other persons we ensure that your information is being protected and used only within the purposes specified in Section 4 of this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors as well as taking technical measures to ensure the information is protected when stored, used and while being transferred.


5.4. You also have to be aware of the fact that Fairspin may disclose your personal information to enforce and comply with the law. In other words, Fairspin may disclose to officials’ information necessary for the investigation or legal process on official request or the official bodies acting within their powers.


5.5. Your personal information will be stored by Fairspin within the term of your use of the Platform and up to your termination of such use. Fairspin shall terminate the processing of your personal information unless the special retention period for the storage of such data is set by the relevant legislation.

6. RIGHTS AND OBLIGATIONS OF THE PARTIES 
 

6.1. The User’s Rights - to request Fairspin to access to your personal information. 
  That means that you can ask Fairspin what personal information of yours is being processed as well as for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information.


- to request Fairspin to rectify your personal information.  
  This means you can ask all the inaccurate personal information concerning you being corrected. You can also complete the personal information if you feel there is a need to do so.


- to request Fairspin to erase personal information. 
  
  You can request Fairspin to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases Fairspin will erase it unless otherwise will be required by legislation.

- to request Fairspin to restrict the processing of your personal information.   
  In some cases, prescribed by law you will be able to restrict the processing of your personal data, for example if you contest the accuracy of your personal information being processed or in case Fairspin will not be interested to process your personal information any longer, but you will want Fairspin to do this on different reasons, for example, to bring some claim for somebody and instead of the erasure of information its processing will be just restricted.


- to withdraw consent.    
  You can withdraw your consent for the collection and processing of your personal information by Fairspin at any time, without affecting the lawfulness of processing based on consent before its withdrawal. After we at Fairspin receive such withdrawal from you we will process it in a timely manner and no longer process such information unless the obligation to proceed is set by law. The phrase “in timely manner” is deciphered below. 
Fairspin will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Fairspin is overwhelmed by the number of the requests. Fairspin will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

- You also have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country.

6.2. The User’s Obligations

The User is fully aware that sending a notice of disagreement with any of the purposes of personal data processing and/ or of intention to stop processing of his personal data being made by the Fairspin shall be the legal ground for the termination of any relationships between the Parties within the Terms & Conditions placed on this website.

You are solely responsible for the veracity, accuracy and timeliness of Your personal data being provided to the Fairspin.

6.3. The Fairspin Rights

6.4. The Fairspin Obligations

6.4.1. The Fairspin is obliged to report any correction or erasure of personal data, or restriction of the processing of the User's personal data to every third party to whom the User's personal data have been disclosed by the Fairspin for any of data processing purposes established by this Policy, unless this proves impossible or involves disproportionate effort for the Fairspin;

The parties also have all rights and obligations provided by the General Data Protection Regulation.

6.4.2. The time period of storing Your personal data by the Fairspin extends for the entire period of the duration of relationships between the parties provided by the Terms & Conditions placed on the Fairspin website as well as for the next three years after the termination of the Parties' relationships (to resolve possible disputable issues).

6.4.3. Fairspin will ensure that Personal Data is:

6.4.4. The processing of the personal data of a child will be done only where the child is at least 16 years old.

7. PERSONAL INFORMATION PROTECTION 


7.1. Fairspin takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, Fairspin uses verified contractors that might have access to the data as specified in Section 5 of the Privacy Policy with which the relevant data processing agreements are sinned and strives the data is being processed is encrypted and/or anonymized.

7.2. However, we cannot assure you that personal information will never be used or disclosed in a manner that is inconsistent with this Policy. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of such personal information at any time. You should understand that no feasible system of data security is invulnerable. Accordingly, we cannot guarantee the 100% security of your information.

8. LEGAL PROTECTION

The Сompany must comply with the Law on the Processing of Personal Data (Protection of the Individual), no. 138(I)/2001 dated November 23, 2001, as amended; with General Information Protection Regulation (Regulation (EU) 2016/679) and Electronic Communications Privacy Directive (Directive 2002/58 / EC) as amended by Directive 2009/136 / EC applied to EU residents only.

10. CHILDREN'S PRIVACY POLICY

10.1. The privacy of children is one of our concerns as well. Fairspin provides the Services only in case you as the User is aged 18 or older and is fully able and legally competent to use the Website according to the applicable laws.


We hope this Privacy Policy helped you to understand how your personal information will be dealt with here at Fairspin. Do not be afraid – we will take care of it in order the Platform will only help you to do your staff and not to be concerned over your privacy at Fairspin. So, enjoy our Platform!

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