Privacy Policy

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Thank you for playing our games! This Privacy Policy describes how we (Time Plus Q Technologies OU, hereinafter Time Plus Q) collect, process, use and share information about you, why we do so, and how you can ensure your privacy is protected at all times.

Our goal is to be a reliable partner that treats your personal data in a respectful manner, in compliance with all applicable regulations, and leads the way when it comes to transparency and fairness.

1. DEFINITIONS

1.1 Data Subject is a natural person about whom Time Plus Q has got information or data enabling to identify the natural person. Data Subjects are, for example, the Clients, Visitors and cooperation partners, as well as the employees who are natural persons and whose personal data are held by Time Plus Q.

1.2 Privacy Policy is this text which sets out the principles for Personal Data Processing by Time Plus Q.

1.3 Personal Data is any information concerning an identified or identifiable natural person.

1.4 Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject, such as collection, recording, organisation, structuring, storage, alteration and disclosure, enabling an access to, retrieval, consultation, use, transmission, cross-checks, alignment or combination, restriction, erasure or destruction of Personal Data, irrespective of the manner of performing these operations or the means exploited.

1.5 Client is any natural or legal person that uses or has expressed a desire to use the Services of Time Plus Q.

1.6 Agreement is the Service Agreement or any other agreement entered into between Time Plus Q and the Client.

1.8 Website means the websites of Time Plus Q.

1.9 Visitor is any person using the Services or Website of Time Plus Q.

1.10 Child's Consent Age in the context of Personal Data Processing is at least 16 years in relation to the offer of information society services directly to a child.

1.11 Services are any services and products offered by Time Plus Q, including the information society services in the Product Portfolio of Time Plus Q.

1.12 Cookies are the data files of the Website sometimes recorded in the device of a Visitor.

1.13 Data Protection Officer of Time Plus Q is the person who monitors the implementation of the Personal Data Processing principles at Time Plus Q and who can be contacted by the Data Subject in case of a complaint.

1.14 Product Portfolio means the business entities, various products and Services of Time Plus Q, the list whereof is available in Time Plus Q Product Portfolio (such as games, Websites).

2. GENERAL PROVISIONS

2.1 Time Plus Q is the legal person Time Plus Q Technologies OU, registry code 12434979, registered address Harju county, Tallinn, J. Vilmsi tn 11-6, 10126.

2.2 Time Plus Q resolves all issues in relation to the protection of Personal Data in Estonia in conjunction and cooperation with the Estonian Data Protection Agency.

2.3 Time Plus Q may process Personal Data as:

1. a controller, while determining the purposes and means of processing;
2. a processor in accordance with the instructions from the controller; and
3. a recipient to the extent to whom the Personal Data are transferred.

2.4 This Privacy Policy of Time Plus Q constitutes an inseparable part of the Agreement entered into between Time Plus Q and the Client.

2.5 The Privacy Policy shall apply to the Data Subjects, and the rights and obligations set out in the Privacy Policy shall be followed by all the employees and cooperation partners of Time Plus Q who come into contact with the Personal Data that are in the possession of Time Plus Q.

3. PRINCIPLES

3.1 The objective of Time Plus Q is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes, and Time Plus Q shall always take into account the interests, rights and freedoms of Data Subjects.

3.2 All the processes, guidelines, operations and activities of Time Plus Q that are related to Personal Data Processing are based on the following principles:

1. Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. consent;
2. Fairness. Personal Data Processing shall be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed;
3. Transparency. Personal Data Processing shall be transparent for the Data Subject, including via this Privacy Policy, which explains why, how and when the Personal Data are processed;
4. Purposefulness. Personal Data shall be collected for legitimate purposes which have been established precisely, clearly and shall not later be processed in any manner which is in conflict with these purposes;
5. Minimisation. Personal Data shall be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data. Time Plus Q shall be guided by the principle of minimal Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or needed for the purposes for which it was collected, the Personal Data shall be deleted;
6. Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay;
7. Limit of storage. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed;
8. Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures;
9. Data protection by design and by default. Time Plus Q shall ensure that all the systems used shall meet the required technical criteria.

4. COMPOSITION OF PERSONAL DATA

4.1 Time Plus Q collects the following types of Personal Data:

1. Personal Data disclosed to Time Plus Q by the Data Subject e.g.:
   • contact information such as nickname and e-mail address; in some cases postal address, telephone number;
   • information on job applicant such as resume, name, e-mail address, telephone number;
   • information provided as an answer to a survey;
   • information provided when creating an account, such as e-mail, nickname, country, age, gender;
   • information provided when inviting others to use Time Plus Q Services;
   • content of the messages sent through Time Plus Q chat channel or messaging system.
2. Personal Data generated as a result of the day-to-day communication between the Data Subject and Time Plus Q;
3. Personal Data manifestly made public by the Data Subject including data from Facebook and Google accounts when used for login;
4. Personal Data generated upon consumption of Services and visiting, using the Website including device information, location data, and game interactions;
5. Information collected using cookies or other similar technologies;
6. Personal Data received from third persons;
7. Personal Data created and combined by Time Plus Q.

5. PROCESSING PURPOSES AND LEGAL BASES

Time Plus Q processes Personal Data based on consent or other legal bases including legitimate interests or contractual necessity. Processing purposes include:

• Providing and improving our services
• Account creation and management
• Communication with users
• Payment processing
• Legal compliance
• Marketing and analytics (with consent)

6. DATA SHARING AND TRANSFER

We may share your Personal Data with trusted third parties including service providers, payment processors, and analytics partners. Any transfers outside the European Union are conducted with appropriate safeguards in place.

7. DATA SECURITY

We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. Personal Data is stored via Amazon Web Services, Google Cloud and in secure servers.

8. CHILDREN'S PRIVACY

We do not knowingly collect information from persons under the age of 16. If we discover that we have collected Personal Data from a child under 16, we will take steps to discontinue processing of such data.

9. YOUR RIGHTS

You have the following rights regarding your Personal Data:

• Right to withdraw consent
• Right to access your data
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to file complaints with supervisory authorities

10. COOKIES AND WEB TECHNOLOGIES

We use cookies and similar technologies to enhance your experience, analyze usage, and provide personalized content. You can control cookie settings through your browser preferences.

11. CONTACT INFORMATION

12. POLICY UPDATES

We may update this Privacy Policy from time to time. We will notify you of any material changes via our website, email, or other appropriate means.

Latest amendments and entry into force: 30 August 2021