Div.Plan Privacy
Policy (the "Policy") Last revised:
15.09.2019 We value Your privacy and respect Your interest in
learning how information about you is collected and used. Plan B, LLC. (the "Owner", 'Div.Plan",
"We", "Our", or "Us", "Data Controller"), which is the owner of Div.Plan App., the website (if
applicable) (referred to as the "App" and the "Site", respectively, and collectively referred to
as the "Software") has developed a Privacy Policy guaranteeing the protection and
confidentiality of the personal data of Users (the "User", "You", or "Your") collected. This
document (Policy) describes how We collect, use, disclose, transfer, and safeguard Your
information.
This Policy is drafted in strict compliance with data protection laws
applicable in relevant jurisdiction and Regulation (EU) 2016/679 (General Data Protection
Regulation), hereinafter referred to as the "GDPR".
1. Acceptance of the
Policy terms 1.1. By using the Software, You are indicating Your express
consent to the terms and conditions of this Privacy Policy. Div.Plan reserves the right to amend
the Privacy Policy at its sole discretion, the revised version will be published in the App or
on the Site. Please check the current version and any amendments to this Privacy Policy as Your
continued use of the Software indicates Your express consent to the amended Privacy Policy.
1.2. If you have a complaint or question about this Policy, if you would like to make a request
concerning your personal data, withdraw Your consent, you may at any time contact us at
support@Div.Plan. We will aim to respond you within maximum 10 business days from receipt of
request. Any correspondence received from You is classified as restricted-access information and
may not be disclosed without Your prior consent.
2. The list and the purpose
of processing Your information 2.1 When You register with the App or
create user account on the Site or use the external accounts (as defined below) to sign in we
collect the following personal information
: (a) first and last
name,
(b) e-mail address,
(c) profile photo,
(d) ID number of the
User's Google account or the account registered with token exchange which may be used for
signing in the App or the Site (the "external account").
If you register in the App or
on the Site without use of external account, we collect and process only your e-mail address if
other information is not indicated by you.
We process your personal information for
the following purposes (i) access and use of the Software, delivery of the Software features as
specified in End-User License Agreement (abbr. "EULA"), (ii) communication with the User with
respect to access, use of the Software, support requests, settlement of complaints, award of
in-app bonuses.
2.2 When You log in the App or the User's account on the Site and use
the Software we collect and process non-identifiable technical information about Your mobile
device or computer and some technical identifiers:
(a) Android or iOS
version,
(b) type and version of operating system,
(c) system language,
(e) IP address.
We collect and process the technical information and identifiers for
the following purposes (i) smooth running and integration of the Software with the User device
and delivery of the Software features, (ii) technical and statistical purposes (including, but
not limited to, product updates, patches and fixes to assure correct operation of the Software).
2.3 Div.Plan Software also automatically collects information about Cookies, which are the text
information located in a temporary file that We send via the web server to the User's device in
order to save the session on the User device, and to identify You the next time You visit the
App or the Site. Cookies do not contain personal User data. These files contain exclusively
technical information that is non-specific and necessary for the identification of the User.
Some of Our partners may also use cookies: for example, when placing advertisements. Please note
that We do not have access to such cookies. Our partners' cookies are regulated by their own
privacy policies.
You are not required to accept cookies. If you want to turn off
cookies in your web browser, follow the instructions for your browser:
Mozilla Firefox
http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=?Enabling+and+disabling+cookies
Chrome
http://support.google.com/chrome/bin/?answer.py?hl=en-GB&answer=95647
Safari (OS X)
http://support.apple.com/kb/HT1677
Additional information on placement, use, and deletion of cookies can be found at
http://www.cookiecentral.com/faq and
http://www.aboutcookies.org.
2.4 The
Software contains some elements developed by third parties ("Third Parties SDK"). To Our best
knowledge, such third parties through Third Parties SDK collect and process personal data on a
legal basis and with responsible approach to personal data protection. Moreover, in any case
they are well known companies with respected reputation and We always negotiate the necessity to
process Your personal data. However, We do not make decisions about the information processed by
these third parties and purposes of processing. Therefore, We do not include information on
exact actions and purposes of personal data collection of mentioned third parties.
In
the list below You can find the information about Third Parties SDK and direct links to texts of
privacy policies developed by such third parties:
Company Name
Third Party software Purpose of third party software Information
or link to privacy policy Google, Inc. Google Analytics Statistics
https://policies.google.com/privacy Third
parties Google Analytics place a permanent cookie-files (mostly for statistical reasons) to your
web browser to identify you as a unique user the next time you visit the App, it helps us to
collect statistics about how the Software is used so we can improve it. These cookie-files do
not collect person identifiable information. The information collected using the cookies will be
transmitted to Google, Inc. Processing of personal data by Google, Inc. is regulated by the
privacy policies of these companies indicated in the table above. We would like to underline
that We use the information obtained through Google Analytics only to exercise our obligations
under the EULA entered into with the User, improve our App. and deliver in-app service to the
User. To ensure security of your information We do not combine the non-identifiable information
received through Google Analytics with person identifiable information We collect.
You
can disable Google Analytics to recognize you when you return to the App by the following means:
1) for disabling Google Analytics - by opting out Google Analytics cookies in your browser, or
(ii) you can use Google Analytics Blocker.
2.5. We do not collect or process any of
sensitive data unless it is required to be law such as in the event of a court case. Under most
circumstances, the types of data listed below will be never be processed:
(a) Race or
ethnic origin,
(b) Political opinions,
(c) Religious or philosophical
beliefs,
(d) Trade union memberships,
(e) Genetic or biometric
data,
(f) Health or mortality,
(d) Sex life or sexual orientation.
3. Legal basis for processing personal data 3.1 We will only collect
and process personal information about You where we have legal basis. Legal basis may include
your consent to process personal data, contract and "legitimate interests".
Type
of your data Legal basis Personal information (a) first and last
name, (b) e-mail address, (c) profile photo, (d) ID number of the User external account. (a)
execution of contract entered between You and Div.Plan (End-User License Agreement, "EULA"), (b)
legitimate interest: establishment, exercise or defense of your legal claims or legal claims of
our partners Non-identifiable information (a) Android or iOS version, (b) type and version of
operating system, (c) system language, (e) IP address, (d) Cookies (a) execution of contract
entered between You and Div.Plan (EULA), including, without limitation, assuring your enjoyable
use of the Software, (b) legitimate interest: establishment, exercise or defense of your legal
claims or legal claims of our partners, compliance with any laws and regulations applicable to
delivery of the Software to You.
4. Children The Software is not
designed for persons under 18 (or the minimum legal age to consent to the collection and
processing of personal data if different under applicable law of relevant jurisdiction). While
GDPR specifies that different countries may provide by law for a lower age provided that such
lower age is not below 13 years, we do not knowingly collect information from children under 13
as well. If we discover that a child under 13 has provided Us with personal information, We will
delete such information from Our systems.
5. How long We store your personal
information 5.1. We retain personal information for as long as necessary
to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory
obligations (no longer than is necessary for the purposes for which your personal data is
processed). In accordance with our record keeping obligations, we will retain basic account
information and information about performed transactions for at least 10 years after an account
is closed.
5.2. If You submit a request to be forgotten, We will anonymize your
personal data unless we have a legal obligation to continue to store the personal data, or for
the establishment, exercise or defense of a legal claim. For example, if you have redeemed a
reward within any of our applications we may store your personal data for as long the statute of
limitations for making a claim relating to that redemption. If you have indicated in any way
that you believe you have a dispute with us, we may store your personal data at least until that
dispute is resolved.
5.3. We may store anonymized data indefinitely. We maintain this
type of data to compare performance of our Site, our Applications and our Services over past
periods, to analyze current performance, to measure player activity over time, and for other
business uses.
6. How We Share Your Information We may
share the information that we receive from You, including personally identifiable information,
as follows:
6.1. Our Users. Your username and any information that you post,
including, without limitation, reviews, comments, scores, and text will be available to, and
searchable by, all other Our Users.
6.2. Service Providers. We may disclose the
information we collect from you to third party vendors, service providers, contractors or agents
who perform functions on our behalf.
7. Disclosure of your
information 7.1. We may be required to disclose Your personal information
in accordance with the law, a legal process, or court proceedings, and/or on the basis of public
inquiries or inquiries by government agencies inside or outside the country in which You are
located.
7.2. We may also disclose information about You if We determine that such
disclosure is necessary or appropriate for the purposes of national security, law enforcement,
or other instances of public importance.
7.3. We may also disclose information about
You if We determine that such disclosure is necessary in order to execute Our regulations and
conditions, or for the purposes of protecting Our activity and Our users. Additionally, in the
event of the reorganization, merger, or sale of the company, We may transfer any or all of the
personal information We have collected to the relevant third party.
7.4. We do not
sell or in any way provide personal information of Our users to third parties. This does not
include trusted third parties which are providing Us with services concerned with the operation
of the Website / App or management of Our business, as well as any other services. Information
about You may be processed by Us and other members of Our corporate group and Our partners. Such
parties are required to rigorously monitor and accept the regulations of this Privacy Policy.
Information about You may be processed both within and outside the jurisdictions of the
EEC.
7.5. In addition to the disclosure of information in accordance with Clauses
7.1–7.4 of this Privacy Policy, We may also disclose information about You to Our employees and
the employees of other companies in Our corporate group. All parties receiving information about
You are required to comply with current data protection legislation and ensure the
confidentiality of Your information to the same extent to which We are bound by those
obligations.
8. Security and access to your information
8.1. We strive to maintain maximum accuracy of the information about You that We have at Our
disposal. You can contact Our technical support service at any time at support@Div.Plan in order
to review, change, or receive a copy of the information about You, or for the purpose of making
necessary amendments to that information. The following options regarding Your right in details
are listed below:
(a) Delete data: You can request deletion of your personal data that
we have about you. We will delete the data and since some of the data is necessary to provide
services to you, you will not be able to use services after the deletion;
(b) Change
or correct data: You have the right to request change of incorrect personal data that we have
about you;
(c) Object to or limit or restrict use of data: You can request that we
stop using all or some of your personal data (e.g., if we have no legal right to keep using it)
or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully
held);
(d) Right to access and/or take your personal data: You have the right to ask
us for a copy of your personal data and can ask for a copy of personal data;
(e) You
also have the right to lodge a complaint at a supervisory authority.
8.2. In certain
circumstances, We may charge a minimal fee to cover administrative expenses connected with any
request made by You in that regard.
8.3. Please read Chapter 3 "Rights of the data
subject" (
here) of the Regulation (EU) 2016/679 (General
Data Protection Regulation) to learn more what your rights are.
9. Where We
Hold Your Information Personal information We collect may be stored and
processed for the purposes set out in this document in any country in which We operate and your
personal information may be transferred, stored and processed by recipients in various countries
around the world where other users or our partners are located. We do our best to make sure all
recipients or your personal data understand the necessity to process personal data only on a
legal basis taking into account any and all applicable legislation.
Aiming the
appropriate security and protection of data collected we located our servers with personal data
of our users in Germany
, the member state of EU,
recognized by the European Commission as the country providing adequate measures on
protection of personal data information in accordance with GDPR. 10.
Changing and deletion of the account in the App or on the Site 10.1.
Users may change your personal data in the App or on the Site in your account area, or delete
information in the User Account record by sending a message to the support service at
support@Div.Plan. Your account will be deleted and your personal data will be de-personalized
within 30 days of receiving your request.
10.2. We retain your personal data even
after You have closed Your account if reasonably necessary to comply with our legal obligations,
meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse or
enforce our EULA. We will retain de-personalized data after Your account has been
deleted.
11. Protection of personal information 11.1. We
make significant efforts, including taking every administrative, technical, and physical
precautionary measure within its power, to protect Your personal information from loss, theft,
and dishonest use, as well as from unauthorized access, disclosure, amendment, and deletion.
Even so, no security measure is 100% perfect. Therefore, while We strive to employ reasonable
protections for your information that are appropriate to its sensitivity, We cannot guarantee
the security of your information and do not assume any responsibility for the unauthorized use
or access to Your information under Our control.
11.2. Pseudonymous information (in
such a way that the individual is not or no longer identifiable), which We are not in position
to relate to You, does not qualify as "Personal Information". All collected information is
pseudonymised. Neither We nor any third party may identify You. If any personal data which could
let Us identify You is collected, it is always automatically pseudonymised.
11.3. The
personal information You post on social networks, on forums, or in chat rooms is visible to
other users and may be read, collected, or used by them. You are responsible for the personal
information that You prefer to provide in such cases.
11.4. You should take steps to
protect against unauthorized access to Your password, and mobile device or computer by, among
other things, signing off after using a shared computer, choosing a robust password that nobody
else knows or can easily guess, and keeping your password private. We are not responsible for
any lost, stolen, or compromised passwords or for any activity on your account via unauthorized
password activity. To change Your external account's password, you must go to the relevant third
party site and follow its procedures for changing your password.
12.
AMENDMENTS TO THE PRIVACY POLICY 12.1. We reserve the right to amend this
Privacy Policy at any time. Amendments to the Privacy Policy shall come into force immediately
after the revised version is published in the App or on the Website.
13.
APPLICABLE LAW When processing Your personal data, We rigorously try to
comply with the regulations of English Common Law, including the Data Protection Act 1998 and
Regulation (EU) 2016/679 (General Data Protection Regulation).
14. ABOUT
US Plan B, LLC. Registration number:
1177847203522, INN 7813280830, Tel. (812)677-30-83 ,
Legal address: 197110,
Sankt-Peterburg, Krasnogo Kursanta street, 25, lit. ZH, №2-GK