Data Protection Policy

The Chick Game Studios LTD

The Chick Game Studios ('Company', 'we', 'us', or 'our') (hereinafter – The Chick Game Studios) is committed to respecting your privacy and protecting your personal data. This data protection policy (hereinafter – Policy) is effective from 1 June, 2023 (hereinafter – Effective Date).

All personal data is obtained, held, and processed by The Chick Game Studios, in compliance with this Policy, any and all data protection related laws and regulations that are applicable to The Chick Game Studios including without limitation, 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, the applicable national data protection law in Latvia, and any data protection related terms in any agreement or contract in force between The Chick Game Studios and its customers in relation to the supply by The Chick Game Studios of services and/or products.

Definitions

  • GDPR

    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).

  • Personal Data

    Any information relating to and identified or identifiable data subject as defined by applicable law, such as:

    • Coarse location
    • User ID
    • Device ID
    • Purchase history
    • Advertising data
    • Product interaction
    • Other Usage Data
    • Performance Data
    • Other types of Data
  • Data Subject

    An identified or identifiable natural person.

  • Customer

    Natural or legal person who provides The Chick Game Studios with Personal Data.

  • Data Protection Laws

    With relation to Personal Data means GDPR and any other applicable data protection laws.

  • Controller/Processor

    As defined in GDPR.

  • Personal Data Breach

    As defined in GDPR.

  • Data Processing (Process, Processing)

    Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • Services

    Any actions performed by The Chick Game Studios to provide the services for the aircraft in accordance with the contracts signed between the Customer and The Chick Game Studios, or Customer's documented instructions, requests, specifications, descriptions, agreements.

  • Responsible Person

    Responsible for Personal data protection in The Chick Game Studios: Project manager, Jana Garancha.

  • Register of Systems

    Register of all systems or contexts in which Personal Data is processed by The Chick Game Studios.

Data Protection Principles

The Chick Game Studios is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that Personal Data shall be:

  • processed lawfully, fairly and in a transparent manner in relation to individuals;
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
  • and processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

General Provisions

This Policy applies to all Personal Data processed by The Chick Game Studios.

The Responsible Person shall take responsibility for The Chick Game Studios' ongoing compliance with this policy.

Any Personal Data provided will only be used in accordance with this Policy. This Policy applies to Personal Data that we collect, use and otherwise Process in connection with The Chick Game Studios relationship with the Customer (use of The Chick Game Studios website or mobile apps).

The Chick Game Studios Services acquired by the Customer from The Chick Game Studios will be subject to their own terms and conditions. In the event of any conflict between this Policy and the terms and conditions of any such Services, then the terms and conditions of those Services shall prevail.

Changes to the Policy

This Policy is effective as of the Effective Date. Last Revised Date appearing at the bottom of this Policy to determine when this Policy was last updated. Any changes or modifications will become effective with the Last Revised Date. Any changes to this Policy will be made as required. If the Policy has been changed in any way, then the latest revision of this Policy will be published on The Chick Game Studios website. Customer is encouraged to check whether any changes have been made to the Policy from time to time.

Customer's access to or use of any of The Chick Game Studios Services is entirely voluntary. Customer's use of Services constitutes Customer's acceptance of all of the terms and practices described in this Policy, including without limitation, the collection, use, processing, and disclosure of Personal Data as described in this Policy.

The Chick Game Studios Services should not be used by the Customer if the Customer disagrees with any part of this Policy.

Any questions or concerns about this Policy or its implementation can be addressed contacting The Chick Game Studios at jana.garanca@apfholdings.lv.

News, publications and events

The Chick Game Studios process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Personal Data will be used for this purpose until The Chick Game Studios shall be informed that Customer no longer wishes to receive such information from us.

Data Minimisation

The Chick Game Studios shall ensure that Personal Data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed.

The Chick Game Studios Obligations

With respect to the Services, The Chick Game Studios is the Processor of Personal Data and Customer is the Controller of Personal Data.

The Chick Game Studios shall Process the Personal Data to perform the Services in accordance with Customer's documented instructions, agreements, specifications, descriptions.

The Chick Game Studios shall maintain the confidentiality of any such Personal Data and shall take reasonable steps to ensure the reliability of any employee, agent or contractor who may have access to the Personal Data, ensuring in each case that access is limited only to those individuals who need to access the relevant Personal Data for the purposes necessary to perform the Services.

To the extent that The Chick Game Studios experiences a Personal data Breach with respect to the Personal Data that The Chick Game Studios Processes as part of its performance of the Services, The Chick Game Studios will notify Customer promptly upon becoming aware of such Personal Data Breach.

The Chick Game Studios will provide all reasonable assistance to Customer with regards to any issues related to data protection to the extent required by applicable law.

After the end of the provision of Services, The Chick Game Studios shall delete all copies of Personal Data Processed by The Chick Game Studios in accordance with The Chick Game Studios company procedures on data protection.

Customer Responsibilities

In performing the Services on behalf of the Customer, The Chick Game Studios is relying on the following information to be true and accurate:

  • the Customer is the Controller and The Chick Game Studios is the Processor acting on the Customer's behalf;
  • the Customer shall comply with the applicable laws and regulations related to data protection and confidentiality;
  • the Customer shall be responsible for obtaining the consent of the Data Subject for the Processing of the Personal Data;

To the extent applicable the Customer shall be responsible for notifying or otherwise gaining approval of any regulatory body to the data transfer arrangements.

Location of the Processing of Personal Data

The Chick Game Studios primarily stores and processes Personal Data within the European Union. Nevertheless, it may at times be necessary that Personal Data is transferred to and stored at a destination outside the European Union. It may also be processed by data processors operating outside the EU.

By submitting Personal Data to The Chick Game Studios or by consenting to the processing of Personal Data Customer agrees to the processing of Personal Data, including both data storage and data transfer, outside the EU for the purposes set out in this Policy. The Chick Game Studios shall take all reasonably necessary precautions to ensure that transferred Personal Data is treated securely and in accordance with the applicable Data Protection Laws.

Transfer of Personal Data to Third Parties

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

Access, Review, Transfer and Deletion of Personal Data

Customer among other rights has the right to request from The Chick Game Studios erasure of Personal Data or restriction of processing.

Last Revised Date: 19 June, 2023