PRIVACY POLICY

1. Subject
This Privacy Policy describes Natus Vincere (“Navi”) actions with your Personal Data provided via our gaming Site located at: http://navi.gg/ (the “Site”).
Our Privacy Policy is based on the EU General Data Protection Regulation (hereinafter the “GDPR”), Internet ethic, common practice and Navi policies with regard to the protection of your Personal Data aligned with applicable law.
By the registering on the Site, using it and reading this Privacy Policy, you:
provide your consent to us for processing your Personal Data for contacting purposes (in case you send us a request for information);
provide your consent to us for processing your Personal Data for website utilization purposes;
provide your consent to us for processing your Personal Data for the analysis of your actions on the Site;and
are deemed notified of such processing.
If you disagree with this Privacy Policy, or cannot accept its provisions, please refrain from using the Site and Navi Services.
If any provision of this Privacy Policy is unclear for you or you would like to obtain more information or ask any question, please contact us at: [email protected].
Once you accept the Privacy Policy, you hereby agree and acknowledge that, we may modify (update or amend) the Privacy Policy by posting the modified version on the Site at any time and at our sole discretion. All modified versions shall take effect immediately after posting on the Site. You agree and consent to any and all modified versions of the Privacy Policy hereunder, in case you continue using the Site and / or the Services after the modified version is posted, and you are solely responsible for regularly reviewing the Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.
2. Definitions
For the purposes hereof, the following terms shall have the following meanings:

“Account” - means the account that must be created to become a User and access the Services offered by Navi and differentiate users from another;

“Personal Data” – means any data by which you as an individual can be identified, e.g., name, profile photo, date of birth, location data;

“Services” - all services related to the games and delivered by Navi via the Site;

“User” - any individual having created an Account on the Site and using the Services.

3. Collected Personal Data and its sources
When you create or modify your Account, when you use the Site and the Services, including creation of a team for the game, when you provide the Personal Data directly to us by contacting customer support or otherwise communicating with us, we may collect the following data, which may contain Personal Data of you, but is not limited to:
name, username, nickname;
e-mail address;
password;
preferred language of speaking;
city and country of inhabitancy;
profile picture / avatar;
date of birth;
link to the Steam-platform, or Facebook, or Vkontakte, or Twitter, or Instagram;
level of game-skill and role in appropriate video-game;
your computer software and hardware in use;
any other information, you choose to provide, or which may be required for the use of the Site and the Services.
We will also collect the following general categories of data, which may contain also Personal Data:
Transaction information:
We collect transaction details related to your use of our Services, including the type of Service requested, date and time the Services were provided, , and other related details when you use the Site. Please note, that we do not collect your payment details.
Usage and preference information:
We collect information about how you and other users interact with the Site, preferences expressed, and settings chosen. In some cases, we do this by using cookies, web beacons and similar technologies that create and maintain unique identifiers.
Device information:
We may collect information about your hardware device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information and network information.
Log data:
When you interact with the Site, we collect server logs, which may include information like the device IP address, operating system, access dates and times, features or pages viewed, system crashes and other system activity, type of browser, and the third-party websites or services you were using before interacting with the Site or were proceeding from the Site.
Account information:
To access and use the Site and the Services, you shall register for an Account by authorization through one of yours social media profile (or Facebook, or Vkontakte, or Twitter, or Steam). After registering, you shall fill in all mandatory fields with accurate, current and complete information about yourself as prompted in the registration form and keep this information up to date. Navi has the right to suspend or terminate your Account and refuse any and all use of the Site and the Services if it suspects that your Account information is inaccurate, not current, incomplete or belongs to another person.
You agree to immediately notify Navi of any unauthorized use of your password or username or any other breach of security.
Please note that, in some cases, we will retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have if we believe you have committed fraud or violated our Privacy Policy, we may seek to resolve the issue before deleting your information.
Your Personal Data voluntarily provided to us must be true, permissible, accurate, and non-fraudulent. It is strictly forbidden to register or operate Account of any third person and the breach of such obligations may cause deletion of the Account by Navi.
We may also receive information from other sources and combine that with information we collect through our Site and Services. For example, if you choose to link your Navi Account with a messaging service or social media service (e.g., Facebook), or if you engage with a separate application or website that uses our API (or whose API we use), we may receive information about you or your connections from that website or application. Also, this kind of information may contain your Personal Data.
4. Our actions with Personal Data
We will mainly perform the following processing actions with your Personal Data:
storage;
compilation;
archiving;
transferring;
changing;
evaluating;
accessing; and/or
deleting.
We will use your Personal Data to:
identify and authenticate Users, provide, maintain, and improve our Site and our Services, including, for example, the provision of products and services you request (and send related information), develop new features, provide customer support, develop safety features, and issue software updates and administrative messages;
perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends;
send you communications that we think will be interesting for you, including information about the Site and the Services, promotions, news, and events of Navi and other companies (including special offers and promotions), where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfil any related awards; we will send you such materials based on the procedures prescribed in clause 5 below;
personalize, develop and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements, marketing, lead generation, analytics, industry and market research, and such other purposes consistent with legitimate business needs of Navi.
We will also transfer your Personal Data from the European Economic Area (hereinafter the “EEA”) to outside the EEA (e.g., from our servers located in the EEA to our offices located outside of the EEA). Where this is the case, we will take appropriate measures to protect your Personal Data in accordance with the GDPR, this Privacy Policy, and our Cross-Border Transfer Policy which have the aim to safeguard this kind of transfers.
5. Processing Personal Data for marketing purposes
Navi processes your Personal Data for marketing purposes based on legitimate interests and based on the relationship you entered with Navi, its Site and/or Services.
Navi may send emails to you with regard to its website functionality or other messages which may also contain marketing materials related to Navi Services you registered for or you showed interest in. The processing of your personal data for such marketing purposes would be based on a legitimate interest of Navi.
You herewith further provide Navi with your consent for the use of your personal data for marketing purposes which are not directly connected to the services you registered for or you showed interest in.
In any case of received marketing emails from Navi, either based on legitimate interest of Navi or based on your consent, you as a data subject always have the right to withdraw from your consent and/or to unsubscribe from our marketing emails at any time. You may “opt out” of receiving marketing or promotional materials by following the instructions in our marketing emails or by e-mailing us at [email protected] to indicate your choice.
6. Security
Navi uses a variety of security measures to keep your Personal Data protected from unauthorised access or disclosure. Navi has security measures in place that are fully compliant with the GDPR to protect the loss, misuse and alteration of the Personal Data under our control. We process your Personal Data based on the following principles:
Fairness and lawfulness:
we process your Personal Data only after ensuring that the processing is based on your consent or other legal grounds for processing, and for a determined specific purpose;
Transparency:
we process your Personal Data in a transparent manner, and only with your knowledge; .
Purpose limitation:
your Personal Data is processed within the purposes outlined above;
Data minimization:
we only process your Personal Data to the extent that it is actually needed to achieve the processing purposes;
Accuracy:
we ensure that your Personal Data is accurate and kept up to date;
Storage limitation:
your Personal Data will be processed for the limited period of 5 years, if no other contractual obligations with you allow a longer time period;
Integrity and confidentiality:
we secure your Personal Data with suitable organizational and technical measures (e.g., our system servers are protected by the leading firewalls; our secure server software is the industry standard and among the best software available today for secure commerce transactions. It encrypts all of your Personal Data granted to us, so we believe that it cannot be read by third parties); and
Accountability:
we will be responsible for and be able to demonstrate compliance with the above-mentioned principles.
7. Access to your Personal Data
Only a limited number of Navi’s functionaries who are responsible for the maintenance of the Site and for customer relations have access to your Personal Data.
8. Disclosure of your Personal Data to third parties
We use our best efforts not to disclose any Personal Data to third parties. Our Site maintains a secure site, but you should know that computer use may be monitored by third parties such as network administrators, employers, internet providers, and operation system & internet browser vendors, and, thus, we cannot guarantee the security of information you post online. You disclose all information online at your own risk. Please remember that this website may be hosted outside your home country, and your email communications to us may be directed to a server that is hosted outside your home country. Communications over the Internet may not be secure.
Navi will disclose your Personal Data to a third party only if you consented to such disclosure or such disclosure is required by the applicable law.
Subject to all applicable laws, Navi may share any information (including your Personal Data and any Navi data) about you:
with the general public if you submit the respective content in a public forum, such as blog comments, social media posts, or other features of our Site and Services that are viewable by the general public;
with third parties with whom you choose to let us share information with, for example other applications or websites that integrate with our API, the Site or Services, or those with an API or Service with which we integrate;
with our subsidiaries and affiliated entities that provide the Services or conduct data processing on our behalf, or for data centralization purposes;
with our vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf and are bound by confidentiality agreements;
with law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our Terms and Conditions, Privacy Policy, or to protect the rights, property, or safety of Navi or others;
in response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
in an aggregated and/or anonymized form which cannot reasonably be used to identify you;
if there is a complaint, dispute or conflict;
if it is required, in our sole discretion, by applicable law, regulation, ordinance, license, or operating agreement;
if it is necessary, in our sole discretion, to protect the safety, rights, property, or security of Navi, the Site, or any third party; to detect, prevent or otherwise address fraud, security or technical issues; and/or to prevent or stop activity which Navi, in our sole discretion, considers to be, or to pose a risk of being, illegal, unethical, or legally actionable; and
if we otherwise notify you and you consent to the sharing.
9. Your privacy rights
If the GDPR is applicable for you, you may have at least the following data subject rights:
the right to obtain any information about processed Personal Data;
the right to access your Personal Data;
the right to withdraw your consent for processing of your Personal Data;
the right to correct and erase your Personal Data;
the right to be aware of any correction or erasure of your Personal Data, restriction of processing, and recipients of your Personal Data;
the right of data portability;
the right not to be subject to a decision based solely on automated processing; and
the right to lodge a complaint with a competent data protection authority.
10. Links to third-party websites
We cannot be responsible for the privacy policies and practices of websites that are not operated by us. We cannot guarantee their absolute security, even if you access them via our Site. We recommend that you check the privacy policy of each website you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you get access to our Site via a third-party website, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party website and recommend that you check the policy of that third-party website and contact its owner or operator if you have any concerns or questions.
11. Restrictions and limitations
In case you reside or are located in a state on which a US-initiated embargo is imposed, or you are included in the list of specially designated nationals or persons unauthorized by the US Department of the Treasury, you declare that you shall not conduct business activity on the Site or use Services for commercial purposes, or even administer on the Site. You also shall not use the Site in case you are forbidden to receive software, products or services, developed or produced in the territory of the United States. The abovementioned restrictions refer to applicable law and in no case are to be deemed an act of discrimination.
12. Children’s Online Privacy Protection Act
Our Site and Services are directed to the general public. We do not knowingly collect information from children under 16 years old or have any reasonable grounds for believing that children under the age of 16 are accessing our Site or using our Services.
NOTICE TO PARENTS AND OTHER LEGAL GUARDIANS OF MINOR USERS:
By granting your child permission to use the Site, you agree to the terms of this Privacy Policy on behalf of your child. You are responsible for monitoring and supervising your child's use of the Site. You are responsible and liable for your child’s online activities on the Site.
If your child is using the Site and is under 16 years old, please provide us with an informal email to the following email address: [email protected], stating that you as the legal guardian of the minor user provide explicit consent for the use of our Site and Services.
In case you do not approve the use of our Site and Services by the minor user, please contact and inform us immediately so that we can disable his or her access.
If you have questions about whether the Site is appropriate for your child, please contact us under [email protected].
13. Cookies, web beacons and IP address
A cookie is a piece of data stored locally on your computer, which contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to the Site.
On the Site, we use cookies to track users’ progress through the Site, allowing us to make improvements based on usage data. We also use cookies if you log in to the Site to enable you to remain logged in. A cookie helps you to get the best out of the Site and helps us to provide you with a more customised Service.
Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browser settings, you should go to your advanced preferences.
If you continue to use our Site we assume you agree to our use of cookies as described above.
If you choose not to accept the cookies, this will not affect your access to the majority of information available on the Site. However, you will not be able to make full use of our online Services and even log-in into your Account and use your Personal Data therefrom, but however you will be able to browse through the website and see public pages thereon.
A web beacon, also referred to as a clear gif or page tag, consists of code on the Site that delivers a small graphic image from another website or third-party server. They may not be visible as the beacon is generally a 1x1 pixel that is often designed to blend into the background of a webpage.
We use web beacons, often in conjunction with cookies, to monitor the effectiveness of ad banners; and to gather general log, statistical, and referral information. We do not use beacons to store or link to Personal Data. We thus use beacons to understand certain actions that you took (such as a purchase), but not to identify you.
Please note, any interaction with the Site may reveal your Internet protocol (IP) address. We may use your (IP) address to help diagnose problems with our Site, to administer the Site, or to gather demographic information about our Users. Your IP address may also be used to assist in the detection of fraud and we may pass this information to the legal bodies for that purpose.
If you have any questions about this Privacy Policy or would like to have access to your data, please contact our Data Protection Officer at [email protected].
Thank you!
Revision: 25 May 2018
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