Privacy policy

1. Introduction

We attach great importance to protecting your data. We have established security and confidentiality rules to ensure the best possible protection of your data. However, we need to collect certain information when you place an order. Please note that personal data is not collected without your prior consent. In this document ("Privacy Policy") we explain how and why we process your personal data on our Website. In this document, we also inform you what rights you have as a personal data subject.

Certain terms used in the Privacy Policy, beginning with a capital letter which are not defined in this document, have the same meaning as given in the Terms and Conditions (“T&C”) of the Website.

We ensure that the personal data we obtain, is processed in a lawful manner and for legitimate purposes. We respect the right to privacy protection and ensure that your personal data is properly secured. Your personal data is processed in particular in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) also referred to as "GDPR". The official text of the GDPR: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

2. Data controller

For the purposes of the data processing and control, the relevant legal entity is Floweo Digital Limited a company incorporated under the laws of Cyprus under the number 435881, registered office address and place of business: Arch. Makariou & Evagorou, 1-7 MITSI 3, 1st floor, Flat/Office 102, 1065, Nicosia, Cyprus acting as business partner and services provider of Gameseal FZE a company registered in the United Arab Emirates under the laws of the United Arab Emirates, formation number 4203495, based in the United Arab Emirates, with address: Business Center, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates.

Contact details:

Correspondence address: Arch. Makariou & Evagorou, 1-7 MITSI 3, 1st floor, Flat/Office 102, 1065, Nicosia, Cyprus;
E-mail address: [email protected] and [email protected];
You can also contact us by using contact forms or support systems available on the Website.

3. Who does this privacy notice apply to?

This privacy notice applies to individuals who access, browse and use our website. Its aim is to give you information on how we collect and process your personal data through your use of the website. We collect personal data when you access our website, register with us, contact us, send us feedback and product reviews, purchase Codes and other products via our website, post material to our website, request marketing updates and take part in promotions, surveys, affiliation or partnership programs via our website.

If you are an Floweo Digital Limited partner this privacy notice applies to you like any other user of the website. However, we will also process certain personal data relating to you in order to perform our partnership agreement with you.

It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your personal data.

4. What personal data we process?

The Administrator processes the following personal data of the Users on the Website:

First name and last name;
User’s name (nick) on the Website;
E-mail address;
User's data from social media (if the User connects his Account with a social media account or uses "plugins" on the Website);
IP address.

It may happen that the Administrator will also process other personal data that the User provides to us on his/her own.

5. How your personal data is collected

We obtain information about Users through the Website, for example in the following way:

Through your use of the Website, when User provides information about himself/herself in the Website, e.g. when the User registers an Account or makes a purchase;
When User contacts the Administrator using the forms available on the Website;
When we contact you e.g. when we ask you to give us your opinion about your purchase;
In the automated manner when you use the Website, e.g. by saving cookies.

6. Security

We take reasonable steps to ensure that your personal information is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In order to minimise the likelihood of security breaches, we do not publicly disclose the nature of such security measures.

However, please remember that using the Internet always carries the risk of specific security incidents, but we assure you that thanks to the implemented procedures we aim at reducing this risk as much as it is possible, by regular reviews of IT systems and their updates, as well as active monitoring of critical system points.

7. Use of the data

We will use your data for different purposses and time periods accordingly:

7.1. To allow you to create and manage a user account on our website, and also for the general use of the website content we will use your identity and contact data, profile data. The period for which the data will be processed:

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract;
Necessary for our legitimate interests of enabling users to create and develop personalised accounts, to facilitate purchases and recording of product and service preferences, for running our business and to develop new business.

7.2. To check your age eligibility to buy certain Codes, to process and deliver your order including managing payments, fees, charges and refunds and collecting and recovering money owed to us we will use: identity and contact data, profile data, financial data, transaction data. The period for which the data is processed:

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract;
Necessary for our legitimate interests to administer our services, to collect sums due to us and to keep our records updated;
Necessary to comply with a legal obligation.

7.3. To respond to queries submitted through the website, telephone, social media or other means and to manage our relationship with you. Data that will be processed: Identity and Contact Data, Profile Data, Financial Data, Transaction Data, Technical Data, Usage Data, Marketing and Communications Data. The period for which the data is processed:

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract;
Necessary for our legitimate interests for responding to user queries, attracting new users, affiliates and partners, running our business and to develop new business, keeping our records updated;
Necessary to comply with a legal obligation.

7.4. To administer and protect our business, products, services, networks, systems, the website and data and property hosted on or made available through the website including implementing and monitoring security measures, troubleshooting, data and usage analysis, testing, system maintenance, support, reporting and hosting of data. Data that will be processed: Identity and Contact Data, Profile Data, Financial Data, Transaction Data, Technical Data, Usage Data, Marketing and Communications Data. The period for which the data is processed:

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract;
Necessary to comply with a legal obligation;
Necessary for our legitimate interests for running our business, IT systems administration, network security, to identify and/or prevent fraud, to collate statistical business to enhance our services and business.

7.5. To deliver relevant website content and advertisements to you. Data that will be processed: Identity and Contact Data, Technical Data, Usage Data, Marketing and Communications Data. The period for which the data is processed:

Necessary for our legitimate interests to study how users use our services, to develop them, to grow our business, to improve our marketing strategy and output and to conduct marketing.

7.6. To use data analytics to monitor usage of the website, to measure the performance of the website and to optimise the website. Data that will be processed: Technical Data, Usage Data. The period for which the data is processed:

Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business.

7.7. To make recommendations to you regarding products or services that may be of interest to you. Data that will be processed: Identity and Contact Data, Technical Data, Usage Data, Marketing and Communications Data. The period for which the data is processed:

Necessary for our legitimate interests to develop our products and services, direct market and grow our business.

8. International Transfers

We are located in Nicosia and so your personal data will be received and processed by us in Nicosia. It may be necessary for us to disclose some of your personal data to our Principal - Gameseal FZE who provide us with products. We will ensure that any international transfers of your personal data are in accordance with applicable laws.

9. Your rights

Each data subject has the following rights:

9.1. The right of access to personal data;

9.2. The right to rectify personal data;

9.3. The right to erase personal data;

9.4. The right to request the transfer of personal data;

9.5. The right to object for reasons related to the special situation of the data subject to the processing of their personal data based on the legitimate interest of the Administrator;

9.6. The right to object to the processing of personal data for direct marketing purposes;

9.7. If personal data is processed by the Administrator on the basis of consent - the right to withdraw consent to data processing at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal;

9.8. The right to file a complaint with the supervisory authority.

In order to have ability use the above rights you should contact us using the contact details provided at the beginning of the Privacy Policy.

10. Personal data recipients

Your personal data may be shared by us to third parties. The sharing of personal data is necessary for the provision of Services on the Website and for the fulfillment of our contracts or in order to comply with legal obligation or it is related to our legitimate interest.

The categories of recipients to whom we may share your personal data are as follows:

10.1. Payment operators, handling payments on the Website;

10.2. Service providers who provide us with technical, IT and organizational solutions;

10.3. Entities providing the Administrator with accounting, legal or advisory support;

10.4. Entities who provide us with online advertising targeting and measurement services;

10.5. Gameseal FZE;

10.6. Social media;

10.7. Public authorities - if we are obliged to do so pursuant to a decision of an appropriate public authority.

Personal data may also be shared as a result of the use of the cookies.

11. Cookies

Cookie files (so-called "cookies") are IT data, in particular text files, which are stored on the User's end device and are intended for the use of the Website. In addition, the Administrator uses other technologies, such as scripts or logs, activated when you are using the Website.

Necessary cookies. Necessary cookies enable basic functions of the website. The website will not work properly without these cookies;
Analytical cookies and cookies that improve performance. These cookies collect information on how Users use the Website and Services and allow us to improve the functioning of the Website. An example of analytical cookies are cookies used within Google Analytics;
Functional cookies. These cookies make it possible to remember the choices made by the User while using the Website and Services. As a result, we will try to provide Users with personalized functionalities;
Advertising cookies. The Website uses advertising networks to manage advertising content displayed on the Website. Other entities may use tracking technologies to collect information about your activity on websites in order to deliver advertisements that are assessed as matched for you (e.g. the Google Adwords network).

It is also possible to distinguish the following types of cookies:

Session cookies: they are stored on the User's device and remain there until the end of the browser session;
Persistent cookies: they are stored on the User's device and remain there until they are deleted. Ending a browser session or turning off the device does not delete them from the User's device.

Software for browsing websites (web browsers) usually allows cookies to be stored on the User's end device by default. Users can change the settings in this regard at any moment. The web browser allows you also to delete cookies. It is also possible to automatically block cookies. Detailed information on this subject can be found in the support system of the web browser. Restrictions on the use of cookies may affect some of the functionalities available on the Website. Detailed information on changing cookie settings and their self-removal in the most popular web browsers is available in the help section of the web browser.

Cookies placed on the User's end device may also be used by advertisers and partners cooperating with the Website operator. It is recommended to read the privacy protection policies of these entities to learn about the rules of using cookies in the statistics. Cookies may be used by advertising networks, in particular the Google network, to display advertisements matched to the manner in which the user uses the website. For this purpose, they may keep information about the user's navigation path or the time spent on a given page.ctivated when you are using the Website.

12. Changes of the Privacy Policy

12.1. The Privacy Policy is effective from 01.09.2022.

12.2. We may change the provisions of the Privacy Policy in the future due to important reasons, e.g. if we change the scope of our Services, in case of change of the applicable laws or if our data changes.

12.3. The Administrator will notify the Users about the change in the Privacy Policy by:

12.3.1. A message visible by the User after entering the main page of the Website and a link to the content of the new Privacy Policy;

12.3.2. Sending registered Users information via e-mail about the changes in the Privacy Policy alongside with a link to the consolidated text of the Privacy Policy.

12.4. If you continue to use the Website and our Services after the changes have been made, we will recognize that you have agreed to the changes to the Privacy Policy.

12.5. The Privacy Policy may be available in various language versions, however, in the event of discrepancies between the language versions, the English version will prevail.