Updated: October 27, 2020

This Personal Data Privacy Policy ("Privacy Policy”) applies to all information related directly or indirectly to a specific or identifiable individual (subject of personal data), including personal data within the meaning of applicable law (“Personal Information”) that 1C-777 Limited and/or its affiliates, including those belonging to the same group of companies (“Operator”), may receive information about You in the course of Your use of the Site, as well as any game, application, software, any updates, changes or DLCs (“Game/s”) currently provided on the Site or which will be provided by the Operator or its licensors, as well as in the course of the Operator's performance of any agreements and contracts concluded with You in connection with Your use of the Site and/or the Game. This Privacy Policy is compiled in accordance with the requirements of the 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/GDPR) and other laws on data protection or data privacy in the member States of the European Union and defines the procedure for processing Personal Information and measures to ensure the security of Personal Information.

1. DEFINITION OF TERMS
1.1 The following terms are used in this Privacy Policy:
1.1.1. Site – an Internet site located at: playcaliber.com
1.1.2. You/User – an individual, the subject of Personal Information, any user of the Game, the user and the visitor of the Site.
1.1.3. Controller of Personal Information in relation to our Site and the Games –
1C-777 Limited
Registration address: 32 Kritis Street, Papachristoforou Building, 4th Floor, 3087 Limassol, Cyprus 
1.1.4. Administration – authorized Site management employees acting on behalf of the Operator who organize and (or) process Personal Information, as well as determine the purposes of processing, the list of Personal Information to be processed, actions (operations) performed with Personal Information.
1.1.5. Processing of Personal Information – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with Personal Information, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Information.
1.1.6. Confidentiality of Personal Information – a mandatory requirement for the Operator or other person who has access to Personal Data to prevent their dissemination without the consent of the subject of Personal Information or the presence of other legal grounds.
1.1.7. Cookies – a small piece of data sent by the web server and stored on the User's computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open a page of the Site.

2. GENERAL PROVISIONS
2.1. Your use of the Site means that You agree to this Privacy Policy and the terms of Processing of Personal Information.
2.2. If You do not agree with the terms of the Privacy Policy, You shall stop using the Site, Games and services of the Operator.
2.3. This Privacy Policy applies only to the Site and the Game. The Administration does not control and is not responsible for the third-party sites to which You can click on the links available on the Site.
2.4. The Administration does not verify the accuracy of the Personal Information provided by You.
2.5. If You have any questions regarding this Privacy Policy, our handling of Your data, or our compliance with applicable laws, please contact our Data Protection Officer at:
Authorized representative of 1C-777 Limited for the protection of user data:
32 Kritis Street, Papakristophorou Building, 4 Floor, 3087 Limassol, Cyprus
Email: privacy@playcaliber.com

3. SUBJECT OF THE PRIVACY POLICY
3.1. This Privacy Policy sets out the obligations of the Administration for non-disclosure and ensuring the confidentiality of Personal Information that You provide at the request of the Administration when registering and using the services on the Site, when launching the Game. We may collect Your Personal Information when You register and use our other products (for example, game forums, chat rooms) or provide feedback about our Games.
3.2. The Personal Information allowed for processing under this Privacy Policy includes the following information:
3.2.1. last name, first name, patronymic;
3.2.2. contact phone number;
3.2.3. e-mail address (e-mail);
3.2.4. date of birth.
3.3. The Administration protects the data that is automatically transmitted during the viewing of ad blocks and when visiting the Site pages
• IP address;
• information from cookies;
• information about the browser (or other program that provides access to the display of ads);
• the model of Your device and its properties (GPU, graphics card, resolution, etc.);
• access time;
• address of the page where the ad block is located;
•  referrer (address of the previous page).
3.3.1. Only part of the above data is qualified as Personal Information. Anonymous or depersonalized information that we cannot associate with Your identity does not belong to the category of Personal Information about You (Your data). Some of the data that the Administration collects is not Personal Information and does not allow us to identify You, and the collection of such data is not intended to identify the user. For example, it can be analytical data on the use of the Operator's Games, or aggregated data detailing the number or types of devices used for this purpose.
3.3.2. Disabling cookies may result in the inability to access parts of the Site that require authorization.
3.3.3. The Administration collects statistics about the IP addresses of its visitors. This information is used to identify and solve technical problems, and to monitor the legality of financial payments made.
3.4. Any other Personal Information not specified above (purchase history, browsers and operating systems used, etc.) is subject to safe storage and non-disclosure, except for the cases provided for in clause 5.2. and clause 5.3.of this Privacy Policy.
3.5. We acknowledge that we have a special obligation to protect children's data. We will not intentionally collect children's data or process it without parental consent. For the purposes of this Privacy Policy, „child” means any individual under the age of 18 (or the minimum legal age to consent to the collection and processing of data, if applicable law provides for a different age). If You are a parent or guardian and believe that we have collected Your child's data in violation of the law, please contact us at privacy@playcaliber.com. We will delete this data in accordance with applicable law.
3.6. Information from our partners. In some cases, the Operator receives Your Personal Information as a data processing operator. This means that such data is controlled by our partners, and we use it only in accordance with the instructions of the partners and the requirements of current legislation. We use this data to fulfill our obligations under the End User License Agreement (EULA) and to improve the quality of the Games, as well as if the processing of this data is necessary for us to fulfill a legal obligation.

Payment partners. When You purchase in-game items, in-game currency, or a limited-term premium membership with a credit card, we may receive and process part of Your credit card number, credit card issuer information, and full billing address from our payment partners.

Advertising partners. In order to provide You with in-game items and / or in-game currency to participate in various loyalty programs, we may also receive information from our partners, such as telecommunications companies, banks, cashback services, travel agencies, etc.

Social network. Facebook, YouTube, Instagram, Discord, Twitter, Reddit and other social media accounts have been created to facilitate communication with our players who want to ask questions about our Games or prefer to find out news about our Games on social media. We have created specific game-related group accounts and pages on Facebook, YouTube, Instagram, Discord, Twitter, Reddit and other social media platforms. In addition, we collect information related to Your social media profiles to ensure that Your account or our Games are integrated with such social media websites, such as Your first and last name, username, relevant social media IDs, etc.

4. PURPOSES OF COLLECTING PERSONAL INFORMATION
4.1. The Administration may use Personal Information for the following purposes:
4.1.1. Identification of the user registered on the Site, for placing an order and (or) concluding a Game purchase and sale agreement or a End User License Agreement.
4.1.2. Providing the User with access to the personalized resources of the Site.
4.1.3. Establishing feedback with the User, including sending notifications, requests related to the use of the Site, the provision of services, and the processing of requests and requests from the User.
4.1.4. Determining the User's location to ensure security and prevent fraud.
4.1.5. Confirmation of the accuracy and completeness of the Personal Information provided by the User.
4.1.6. Creation of an account for making purchases, if the User has agreed to create an account.
4.1.7. Notifications of the Site User about the order status.
4.1.8. Processing and receiving payments, confirming tax or tax benefits, challenging the payment.
4.1.9. Providing the User with effective customer and technical support in case of problems related to the use of the Site.
4.1.10. Providing the User with the consent, product updates, special offers, price information, newsletters and other information on behalf of the Administration or on behalf of the Online Store partners.
4.1.11. Detecting, investigating and preventing violations of the Game rules and the End User License Agreement (EULA).
4.1.12. Carrying out advertising activities with the User's consent.
4.1.13. Providing the User with access to the sites or services of the Site's partners in order to receive products, updates and services.

5. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION
5.1. The Operator processes Personal Information only if You fill out and / or send such information Yourself through special forms located on the Site. By filling out the relevant forms and / or sending Your Personal Information to the Operator, You express Your consent to this Privacy Policy. The Operator also processes depersonalized data about the User specified in this Privacy Policy, if this is allowed in the User's browser settings (including the storage of cookies and the use of JavaScript technology). The processing of Personal Information is carried out without a time limit, in any legal way, including in information systems with or without the use of automation tools.
5.2. The User agrees that the Administration has the right to transfer Personal Information to third parties, in particular, courier services, postal organizations, telecommunications operators, solely for the purpose of fulfilling the User's order placed on the Site.
5.3. Personal Information may be transferred to the authorized state authorities only on the grounds and in accordance with the procedure established by the applicable legislation.
5.4. In case of loss or disclosure of Personal Information, the Administration informs the User about the loss or disclosure of Personal Information.
5.5. The Administration takes the necessary organizational and technical measures to protect Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
5.6. The User may always refuse to receive information messages by sending an email to the Operator at the e-mail address privacy@playcaliber.com marked "Opt-out of notifications".

The User may at any time withdraw the consent to the processing of Personal Information and request the deletion of Personal Information, including by deleting the User's account on the Site and in the Game, by sending a notification to the Operator via e-mail to the email address privacy@playcaliber.com marked "Withdrawal of consent to the processing of Personal information".

The User may access its Personal Information at any time, that is, the User has the right to request free provision of (i) information about the storage of Personal Information about this User, (ii) access to Personal Information about this User, as well as (iii) a copy of the stored Personal Information about this User, by sending a notification to the Operator via e-mail to the e-mail address privacy@playcaliber.com with the corresponding request.

The User may change the Personal Information at any time by sending a notification to the Operator via e-mail to the email address privacy@playcaliber.com

5.7. Depersonalized user data collected through the Site's Internet statistics services is used to improve the quality of the Site and its content.
5.8. We may share Personal Information with our affiliates and subsidiaries, suppliers or agents working on our behalf for the purposes set out in this Privacy Policy. For example, we may engage companies to help protect and secure our systems or Games. All our suppliers and agents shall comply with our privacy and data security requirements; they are not allowed to use the Personal Information they receive for any purpose other than those specified by us. Such companies may be located outside the European Economic Area.
5.9. In order to fulfill the terms of the agreement with You and to comply with our legal obligations and interests, we may transfer your Personal Information to third parties of the following categories:

1. Payment Partners: We share with payment service partners Your email address, IP address, in-game purchase information requested by You on the Site, as well as other information that You provide to us for the purpose of making purchases and withdrawal requests.
2. Advertising partners and Advertising performance evaluation: we share Your email address, nickname, IP address, and other information that You provide to facilitate targeting, providing, and evaluating the effectiveness of online advertising on third-party services, as well as to facilitate the transfer of information that may be useful, relevant, or interesting to You, such as allowing You to earn rewards for viewing in-game ads. These individuals may act as our data processors or, in certain cases, decide for themselves how to process your information.
3. Data Storage Partners: Some of the data we collect is stored on the servers of third-party data storage services.
4. Information available to other players: Allowing other players to see Your nickname and Your game statistics within our Games is very important to improve the experience of the Game.
5. Public Information: Our Games may also have bulletin boards, forums, and / or chat rooms where users can exchange ideas and communicate with each other. When posting a message on a bulletin board in a forum or in a chat, keep in mind that this information will be available to everyone on the network; You post it at your own risk and are solely responsible for any information published by You. Your nickname and game statistics may also be available in Game recordings and other videos that the Operator or other players may create and post online. We ask that You do not include any personally identifiable information in Your nickname. To change your nickname, contact the player support service.
6. Government authorities and auditors: Some data is subject to disclosure to government authorities, such as tax and customs authorities, auditors and other competent parties, in accordance with the laws of each local jurisdiction in which we operate.
7. Contests: Our contests, competitions and tournaments ("Contests") may be organized jointly with other parties or offered by others. When You voluntarily participate in a Contest, we disclose Your data in accordance with the official Contest rules, as well as for administrative purposes and in accordance with the requirements of the law (for example, in relation to the list of winners). When You participate in a Contest, we may allow the sponsor and/or other organizations to use Your name, voice, and / or image in advertising or marketing materials, unless prohibited by applicable law.
If Personal Information is disclosed to the Operator's affiliates and subsidiaries, as well as to third parties outside the European Union or the European Economic Area, the Operator guarantees an adequate level of protection of Personal Information, including, but not limited to, the implementation by the Operator's affiliates and subsidiaries and relevant third parties of the European Commission's standard data protection regulations.

6. OBLIGATIONS OF THE PARTIES
6.1. You shall:
6.1.1. Provide the Personal Information necessary to use the Site and / or the Game.
6.1.2. Update, supplement the provided Personal Information in the event of changes to this information.
6.2. The Administration is obliged to:
6.2.1. Use the received Personal Information exclusively for the purposes specified in clause 4 of this Privacy Policy.
6.2.2. To ensure that confidential information is kept secret, not to disclose it without the user's prior written permission, and not to sell, exchange, publish, or otherwise disclose the Personal Information transmitted, with the exception of clause 5.2. and clause 5.3. of this Privacy Policy.
6.2.3. Take precautions to protect the confidentiality of Personal Information in accordance with the procedure usually used to protect this type of information in the existing business turnover.
6.2.4. Block the Personal Information related to the relevant user from the moment of the request or request of the user or his legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification, in case of identification of false Personal Information or illegal actions.

7. LIABILITY OF THE PARTIES
7.1. The Administration, which has not fulfilled its obligations, is liable for losses incurred by the User in connection with the misuse of Personal Information, in accordance with the legislation of the Republic of Cyprus, unless otherwise required by the legislation of the country where the User usually resides, except for the cases provided for in clause 5.2., clause 5.3. and clause 7.2. of this Privacy Policy.
7.2. In case of loss or disclosure of confidential information, the Administration is not responsible if this confidential information:
7.2.1. became public domain before its loss or disclosure;
7.2.2. it was received from a third party before it was received by the Administration;
7.2.3. was disclosed with the User's consent.

8. DISPUTE RESOLUTION
8.1. All disputes in relation to this Privacy Policy are subject to settlement by correspondence and negotiations using the mandatory pre-trial (claim) procedure. If it is impossible to reach an agreement between the Parties through negotiations within sixty (60) calendar days from the date of receipt of the written claim by the other Party, the dispute may be referred by any interested party to the court at the place of registration of the Administrator in accordance with the procedural and substantive law of the state of registration of the Administrator, with the exception of conflict of laws rules.

9. ADDITIONAL TERMS AND CONDITIONS
9.1. The Administration has the right to make changes to this Privacy Policy without the User's consent.
9.2. The amended Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the amended version of the Privacy Policy.

10. OPERATOR'S DETAILS
1C-777 Limited 
Address: 32 Kritis Street, Papachristoforou Building, 4th Floor, 3087 Limassol, Cyprus

11. COOKIE POLICY
11.1. This Site uses a web Analytics service provided by Yandex.Metric provided by the company "YANDEX", 119021, Russia, Moscow, St. L. Tolstoy, 16 (“Yandex”).
11.2. Yandex.Metric uses cookies – small text files that are placed on Your computer to analyze the User activity.
11.3. The information collected through cookies may not identify You, but it may help us to improve the operation of our Site. Information about Your use of this Site collected by cookies will be transmitted to Yandex and stored on a Yandex server in the EU and the Russian Federation. Yandex will process this information to evaluate Your use of the Site, compile reports on our Site activities for us, and provide other services. Yandex processes this information in accordance with the procedure established in the terms of use of the Yandex.Metric service.
11.4. You can opt out of the use of cookies by selecting the appropriate settings in Your browser. You can also use the tool — https://yandex.ru/support/metrika/general/opt-out.html. However, this may affect some of the Site's features. By using this Site, You consent to the processing of data about You by Yandex in the manner and for the purposes specified above.