PRIVACY POLICY
This version of the Privacy Policy came into force on
June 29, 2025
This Privacy Policy (hereinafter referred to as the
“Policy”) describes how Axlebolt LTD (hereinafter
referred to as “Axlebolt”, “we” and
derivatives) and its subsidiaries and affiliated companies
process personal data as part of providing access to
services on the site axlebolt.games
(hereinafter referred to as the “Site”). By using our
Site and/or agreeing to the Policy by filling out the
relevant forms on the Site, you or your legal representative
(hereinafter referred to as the “User”) accept this
Policy.
If you are an underage person, please ask your parents
(legal representative) to read this Policy. For an underage
person, the Policy is accepted by his legal representative.
If you are an underage person and you are unable to present
this Policy to your legal representative, or if you or your
legal representative does not agree with the terms of this
Policy, please stop using the Site immediately.
If a legal representative allows an underage person to use
the Site, we presume that the legal representative has read
and accepted the Policy on behalf of the underage
person.
At the same time, we do not purposefully collect personal
data from Users under 18 since the Site is intended for a
general audience and is targeted at a wide range of
individuals with full legal capacity.
The Policy on https://axlebolt.games/privacy-policy
is the most current version. We may update this Policy
unilaterally over time, in order, inert alia, to
comply with recent changes in applicable legislation and law
enforcement. All changes are effective when posted on this
page. Please review the latest version of this Privacy
Policy on the Site from time to time.
1. WHAT DATA DO
WE COLLECT AND PROCESS?
We process the following information related to Users:
- Contact and personal information (if a User submits their
CV for consideration for our openings);
- Cookies: Technical, sessional and analytical.
We try to minimize the collection of personal data and do
not collect additional information about you.
In order to process User’s data, we obtain consent in
accordance with the Policy. Users have the option to
withdraw their consent at any time or to request the
deletion of any information we have collected, but in this
case, we will be forced to restrict access to certain
features of the Site, including access to the Personal
Account.
In addition to User’s consent, we rely on our legitimate
interest as the legal basis for data processing.
2. ON WHAT BASIS
AND WHAT FOR DO WE PROCESS THIS DATA?
Below you can find the legal basis and purpose for
collecting the personal data listed in Section 1 of this
Policy:
|
Category of data
|
Legal basis
|
Characteristics of data and purpose(s) of
processing
|
|
Contact information
|
Your consent (including those which expressed
in conclusory acts)
|
You can provide us with your contact
information by filling out a request form on the
Site to receive feedback and/or updates from us.
We may use your email address (or whichever
communication method you have chosen as your
primary means of contact) to contact you
regarding various matters. In addition, you may
provide us with your other contact information
of your choice, as described below.
|
|
Personal information
|
Your consent (including those which expressed
in conclusory acts)
|
This type of data may contain personal
information that identifies you personally.
Using the Site, you can send us (by attaching or
sending your CV through the Site or by email)
your CV for employment, which may contain the
following information: Your first name, surname,
gender, age, ethnicity, photo image, place of
residence, hobbies, links to social media
accounts, education, work experience, phone
number, zip code, mailing address, other contact
information, and other personal information you
may put on your resume. When you send us your
CV, it is up to you to determine the specific
amount of your personal information that we
collect and process.
|
|
Analytical, sessional and technical
Cookies
|
·
Consent (including expressed in conclusory
acts)
·
Our legitimate interest in obtaining static
data for market analysis and research and
improvement the quality of services and the
Site
|
Cookies are small text files that are stored on
your device during your visit a website. We use
cookies to anonymously analyze use of the Site,
as well as to provide you with additional
features on the website, facilitate your
interaction with the Site and ensure error-free
use (for example, to make it easier to navigate
the Site or to save your preferences and
settings for your next visit).
|
3. FOR WHAT
PURPOSES DO WE PROCESS PERSONAL DATA?
We process your data in order to provide information
services related to the Site and its functions, as well as
to review CV you have provided. At the same time, we use
your data to contact you as necessary.
We DO NOT process your personal data to sell it.
We also process your personal data where we have a duty to
do so under applicable law.
4. TO WHOM
PERSONAL DATA MAY BE TRANSFERRED
By agreeing to this Policy, you comfirm that you consent to
the transfer of your data pointed in this Policy to our
affiliates and partners that are not affiliated with us.
We do guarantee that agreements entered into with third
parties provide a level of protection no lower than that
provided for in this Policy, which complies with the
requirements of Russian legislation on personal data.
Transfer for commercial purposes
In order to provide you with the best possible user
experience and to comply with the terms of the User
Agreement between you and us, we may share your personal
data with third parties.
We transfer data to third parties for only the following
purposes:
1) Improving the quality of the Site and services
provided, market research
We allow third-party services to collect your data so that
we can provide services to our Users, measure, analyze and
improve Site performance, and continuously update and
improve our Site and services.
We may use this information to correct any errors on the
Site, evaluate our User demographics data and determine
whether new device types need to be supported for the Site,
and determine whether changes to our marketing and
distribution solutions are necessary.
Cookies may be provided and used by us to learn more about
our audience and the effectiveness of the measures we use to
attract interest in our Site and the services on it, the
viability of the services as business projects.
In this regard, the following categories of personal data
may be shared with partners:
- Analytical, sessional and technical Cookies.
The listed data are transferred to the following third
parties:
|
YANDEX, LLC (TIN 7736207543, PSRN
1027700229193). Here
you can read the privacy policy of Yandex
LLC |
|
Google, Inc. (1600 Amphitheatre
Parkway, Mountain
View, California, 94043, США. Here
you can read the privacy policy of Google
LLC |
The information collected by Cookie cannot identify you,
but it can help us improve our Site.
2) Transfer by virtue of law
We may disclose information that you provide in order to
respond to subpoenas, requests, notices, court orders,
requests from public authorities in any proceeding, and to
establish / exercise our rights.
We may also disclose your information to protect from legal
claims if we believe that disclosure is necessary to protect
our rights, your safety or the safety of others, to
investigate fraud, or to respond to a government
request.
We may transfer your information in order to investigate,
prevent or take action regarding illegal activities,
suspected fraud and situations involving potential threats
to the physical safety of any person, or as otherwise
required by law.
5. CAN WE RECEIVE
PERSONAL DATA FROM THIRD PARTIES?
At the present time the functionality and mechanisms of the
Site do not involve the receipt of personal data from third
parties.
6. HOW LONG DO
WE KEEP YOUR PERSONAL DATA?
We will process your personal data for as long as you
continue to use the Site. If you stop using the Site, as a
general rule, we will continue to process your personal data
for the next
2 years
so that you can resume using the Site and we can use the
data for analytical purposes. After that period, we will
delete your personal data. We may also delete your personal
data earlier than the determined period in case we no longer
need it.
Please note that a different processing period may be
stipulated for Cookies.
7. IS USER DATA
IN SECURE?
The security of your personal data is important to us.
We follow generally accepted standards to protect your
information both during transferring and after it is
received. However, no method of transfer over the Internet
or method of electronic storage is 100% secure. Therefore,
we cannot guarantee absolute security.
While no security system is completely secure, we and our
partners take appropriate security measures to protect
against unauthorized access or disclosure of the information
we collect. For Axlebolt, this includes, among other
things:
·
preventing disclosure of your data unless necessary
·
ensuring that all information collected by Axlebolt is
transferred over secure connections,
·
protection and encryption by software with the appropriate
level to protect against unauthorized access.
Our employees and third parties who access your data are
obliged to keep your data confidential.
8. WHAT RIGHTS DO
I HAVE?
For users in the European Union
If you are a resident of the European Union, you have
rights under applicable data protection laws. These
include:
• The right of access. You have the right to request and
receive a copy of your data available to us;
• The right to correction or deletion. You have the right
to request the correction or deletion of your data available
to us;
• The right to restrict processing. You have the right to
restrict the processing of your data at our disposal;
• The right to data portability. You have the right to
transfer your data at our disposal (transfer the data to
another controller). At the same time, we are not
responsible for the compatibility of data with a third-party
service.
In certain circumstances, you may also have the right to
object to the processing of your data. To send such a
request, please use the contact information provided in the
"Contact us" section. We will review any such
request and take action in accordance with applicable data
protection laws.
If we rely on your consent to the processing of your
personal data, you have the right to withdraw your consent
at any time. However, this will not affect the legality of
processing until such consent is revoked. Please also note
that in addition to your consent, we may have other
legitimate grounds for processing certain categories of
data, so if you disagree with their processing, you must
delete your account in the Game.
Transfer of personal data outside the EU. Since some of our
Analytics Services, Advertising Partners, and Third-party
resources for fighting are located in countries outside the
European Union, your personal data may be transferred to
countries that may not provide the same level of data
privacy as the laws of your country of residence. When
transferring data across borders, we rely solely on the
legitimate grounds for such transfer.
Although we and our partners take all reasonable and
necessary measures to protect your personal data from
unauthorized access by third parties, we are obliged to
inform you about the possible risks of such storage of your
personal data in jurisdictions outside the European Union in
accordance with Article 49(1)(a) GDPR.
By agreeing to the processing of your personal data in
accordance with this Privacy Policy, you give us your
express consent to the cross-border transfer of your
personal data.
For residents of the Russian Federation
If you are a personal data subject from the Russian
Federation, then you have the right to ensure the protection
of your rights and freedoms when processing personal Data,
protection of the rights to privacy, personal and family
secrets, in particular you have the right:
• require us, as an operator, to clarify your Personal
data, block or destroy it if the personal data is
incomplete, outdated, inaccurate, illegally obtained or is
not necessary for the stated purpose of processing, as well
as take legal measures to protect your rights;
• to receive information related to the processing of your
Personal Data, including: confirmation of the fact of
processing Personal Data by the operator; legal grounds and
purposes of processing Personal Data; purposes and methods
of processing Personal Data used by the operator; name and
location of the operator, information about persons (except
for employees of the operator) who have access to Personal
Data or to whom Personal Data may be disclosed on the basis
of an agreement with the operator or on the basis of Federal
Law; processed Personal Data related to the relevant
Personal Data subject, the source of their receipt; terms of
processing of Personal Data, including the terms of their
storage; information about the performed or proposed
cross-border data transfer; name or surname, first name,
patronymic and address of the person processing Personal
Data on behalf of the operator, if processing is entrusted
or will be assigned to such a person; other information;
• to protect their rights and legitimate interests,
including compensation for damages and (or) compensation for
moral damage in court.
For residents of Brazil
If Brazilian law applies to the processing of your Personal
Data, you have the right to request from Axlebolt:
• confirmation of the fact of data processing;
• access to processed data;
• correction of incomplete, inaccurate or outdated
data;
• Anonymization, blocking or deletion of unnecessary,
redundant data or data processed in violation of the
provisions of the Brazilian Data Protection Act (LGPD);
• the possibility of transferring data to another service
or product provider through a direct request in accordance
with the requirements of the National Data protection
Authority (ANPD) and taking into account the requirements of
commercial and industrial secrets;
• deletion of personal data processed with your
consent;
• information about public and private organizations with
which Axlebolt has shared data;
• information about the possibility of refusal of consent
and the consequences of such refusal.
You can also withdraw your consent to the processing of
Personal Data, object to the processing carried out on the
basis of one of the situations of refusal of consent, if
there is a violation of the provisions of the LGPD. We do
not make decisions based solely on automated processing of
Personal Data, however, in any case you have the right to
review decisions made solely on the basis of automated
processing of personal data affecting your interests,
including decisions aimed at determining your personal,
professional, consumer and credit profile or other aspects
of your personality.
For data subjects located in the Republic of Turkey
The Personal Data Protection Act No. 6698 (“DPL”) contains
the rights of data subjects accessing services from the
Republic of Turkey. You have the right to contact the data
controller in order to:
• find out if your personal data is being processed;
• request information about whether your personal data has
been processed;
• find out the purpose of processing your personal data and
whether this personal data is used in accordance with the
purpose;
• know the third parties to whom your personal data is
transferred in the country or abroad;
• request correction of incomplete or inaccurate data, if
any;
• request the deletion of your personal data in accordance
with the conditions specified in Article 7 of the DPL;
• request reporting on transactions carried out in certain
cases from third parties to whom your personal data has been
transferred;
• independently object to the occurrence of a result in
relation to this person by analyzing data processed
exclusively using automated systems;
• claim compensation for damages resulting from the illegal
processing of your personal data.
For residents of California
The California Consumer Privacy Protection Act
("CCPA") grants California residents the following
rights:
The right to access/inform. You have the right to request
that we provide you with the following information:
•
categories and specific elements of Personal Data that we
have collected about you over the past 12 months;
•
categories of sources from which we collect Personal
Data;
•
business or commercial purposes for the collection, use,
exchange or sale of Personal Data;
•
the categories of Personal Data that we have disclosed
about you for commercial purposes and the categories of
recipients to whom they have been disclosed;
•
categories of Personal Data that we have sold or
transferred, and categories of third parties to whom each
type of Personal Data has been sold or transferred.
•
The right to delete. You have the right to request that we
delete Personal Data under certain circumstances, with some
exceptions.
•
The right to correction. You have the right to request that
we correct the Personal Data that we store about you if you
believe that it is inaccurate. We may request the relevant
documents from you in connection with your request. After
receiving and validating a request to correct inaccurate
Personal Data, we will make all commercially reasonable
efforts to correct the Personal Data.
•
The right of refusal. We do not sell your Personal Data.
However, in any case, you have the right to refuse the sale
and exchange of your Personal Data.
•
If you wish to opt out of the sale and sharing, except
through Cookies or other online tracking technologies, you
can contact us using the methods listed below in the
"Contact Us" section.
•
The right to non-discrimination. You have the right not to
be discriminated against for exercising the rights set out
in the CCPA.
Contact the data protection authorities
For residents of the European Union: If you live in the
European Union and believe that we are illegally processing
your personal data, you have the right to file a complaint
with the local data protection supervisory authority. You
can find contact information here: https://commission.europa.eu/about-european-commission/contact_en.
For residents of the Russian Federation: if you believe
that your rights are being violated, you can contact the
Authorized Body for the Protection of the rights of personal
data subjects – Federal Service for Supervision of
Communications. You can find contact information at: https://rkn.gov.ru/contacts /.
For residents of Brazil: if you believe that our
interaction with your personal data violates applicable law,
you can send a corresponding request to the Brazilian Data
Protection Authority (ANPD).
For California residents: If you are a CCPA subject, you
have the right to file a complaint with the California Data
Protection Agency at the following email address: [email protected].
For residents of the Republic of Turkey: if you believe
that your rights are being violated, you can contact the
Office for Personal Data Protection. You can find contact
information here: https://www.kvkk.gov.tr/Icerik/6655/Contact-Us.
Contact us
If you want to exercise the above rights or contact us for
another reason, please contact us at [email protected].
You can also write to us at: Christodoulou Chatzipavlou,
221, Helios Court, Flat 401, 3036, Limassol, Cyprus.
Please note that in order to fulfill the request, we may
need additional information to identify the person who
contacted us. If the provision of information may lead to a
violation of the rights and legitimate interests of third
parties, we may refuse to provide information.
To exercise the rights mentioned above, your request must
contain the following information:
• your email address;
• information confirming that you are connected to us, or
information otherwise confirming that we process your
personal data.
9. WHERE IS MY
PERSONAL DATA BEING STORED?
We store data in Germany (Frankfurt), which provides an
adequate level of data protection.
The data is stored by AMAZON WEB SERVICES EMEA SARL (CC OTH
00760863 2022 TR). You can read the privacy policy of AMAZON
WEB SERVICES.
By agreeing to the Policy, you consent to the transfer of
Personal Data to the territory of Germany.
Thank you for choosing our services!
Sincerely yours,
Axlebolt team