1.   WHO ARE WE?

1.1.   GREEN HORSE GAMES SRL, an entity incorporated and functioning in accordance with the laws of Romania, having its registered office at 21, Aleea Fizicienilor Street, 1F block, 2nd stair, 4th floor, flat 27, District 3, Bucharest, Romania, Romania registered with the Trade Registry under no. J40/6025/2013, sole registration code 31624918 ("Company" or "we"), and for the purposes of data protection legislation, we are the “data controller” with regard to the personal data supplied and processed through this website ("Website").

1.2.   This Privacy Policy determines what happens to the personal data that you may supply to us by interacting with the Website.

1.3.   You can find a Table of Contents and a brief summary of this Privacy Policy in the chart below. For further details with regard to the data processing carried out by the Company click to the links in each section of the summary to access the full content of the Privacy Policy relevant to that topic.

2.   Summary

Matter	Information
What and who this Privacy Policy covers?	The Company is the data controller of the personal data we collect from and about you through the Website. This Privacy Policy applies to all users, including those who use the Website without being registered or having subscribed. For further information click here.
What kind of personal data do we collect about you?	The Company may collect personal data from and about you, specifically: contact information: your first and last name, telephone number and e-mail which you provide by filling in forms on the Website; record of the correspondence with the Company, including information provided by you when sending us a question or comment through the Website contact form; additional personal data which is used together with your contact information in the context of marketing promotions, specifically: demographic information - age, sex and location; details of your visits to our Website and the resources that you access. However, we do not collect special categories of personal data relating to you, specifically any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation, or personal data relating to criminal convictions and offences. For further information click here.
Why do we use your personal data and on what legal grounds?	The main reason why we collect personal data about you is to allow you to use the Website or to provide you with our Company services and to allow you to interact with such services. It is not mandatory to provide us with your personal data. However, should you choose not to provide us with your personal data some of the Website's functionalities may be unavailable for your use. We are processing your personal data for direct marketing purposes or in order to enrol you in our marketing promotions based on your explicit, specific, informed and freely given consent which is obtained through a consent form which is made available to you when interacting with us. Every direct marketing message we send you includes an unsubscribe option which you can use to let us know that you no longer wish to receive such marketing communications from us. For further information click here.
How do we process your personal data?	The security of your data is a priority for us. For this purpose, the Company has implemented adequate administrative, technical and physical measures to safeguard your personal data against loss, theft and unauthorized use, disclosure of modification. For further information click here.
Who can access to your personal data?	The Company might share your personal data with: (i) third party providers who act as processors for the Company and/or (ii) Company affiliates. For further information click here.
Is your personal data transferred abroad?	Your personal data will not be transferred to other countries within or outside the European Economic Area (EEA). However, if such transfer will occur in the future, we will always make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data. For further information click here.
Data Retention	We will retain your personal data only for the period necessary to fulfil the purposes for which the personal data was collected as outlined in this Privacy Policy. At the end of the retention period your personal data will be either cancelled, anonymized or aggregated. For further information click here.
What are your rights with regard to your personal data?	You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your personal data, objection to the processing of your data, data portability and various information in relation to any Automated Decision Making and Profiling or the basis for international transfers. You may also exercise a right to complain to the Romanian supervisory authority. For further information click here.
Updates to this Privacy Policy	The Company may modify or update this Privacy Policy also in order to comply with applicable law. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. For further information click here.
How can I contact you with regard to the processing of my personal data?	You can contact us at the following email address [email protected]. For further information click here.

3.   WHAT AND WHO THIS PRIVACY POLICY COVERS?

3.1.   The Company is the data controller with respect to the personal data (i.e. information that identifies a specific person, such as full name or email address) we collect from and about you through the Website or through other type of interactions we have with you, such as in the context of marketing promotions.

3.2.   This Privacy Policy and our Cookies Policy apply to all users, including those who use the Website without being registered or having subscribed to a specific service.

4.   WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

4.1.   The Company may collect personal data from and about you, specifically:

• contact information in the context of you filling in forms or the data required on the Website contact form, specifically: your first and last name, telephone number and email;
• records of the correspondence with the Company, including information provided by you when sending us a question or comment through the Website contact form;
• additional personal data which is used together with your contact information in the context of marketing promotions, specifically: demographic information - age, sex and location;
• details of your visits to our Website and the resources that you access - when you access and interact with the Website, we may collect certain information about those visits. For example, in order to permit your connection to the Website, our servers receive and record information about your computer, device, and browser, including potentially your IP address and browser type. If you access the Website from a mobile device, we may collect a unique device identifier assigned to that device. Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) may also be collected. These technologies may also be used to collect and store information about your usage of the Website, such as pages you have visited, content you have viewed, search queries you have run and any advertisements you have seen. For more information please visit our Cookie Policy.

4.2.   We do not collect special categories of personal data relating to you, specifically any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation, or personal data relating to criminal convictions and offences.

4.3.   We ask that you do not provide us, and you do not disclose, any information included in a special category of personal data or personal data relating to criminal convictions and offences on or through the Website or otherwise.

5.   WHY DO WE COLLECT YOUR PERSONAL DATA?

5.1.   The Personal Data will be processed by the Company in compliance with applicable data protection laws for the following purposes:

Processing purpose	Legal Basis	Type of Personal Data processed
Provide you with customer support and to respond to your inquiries about our services	Processing is necessary for the performance of a contract to which you are a party or in order to take steps, at your request, prior to entering into a contract.	a.   contact information: first and last name; telephone number; email. b.   records of the correspondence with the Company, including information provided by you when sending us a question or comment through the Website contact form
Provide you with direct marketing messages or enrol you in our marketing promotions	Processing is based on your explicit, specific, informed and freely given consent which is obtained through a consent	a.   your contact information outlined above; b.   additional information collected through marketing forms: such as demographic information - age, sex and location
Allow you to use the Website and improve your experience on the Website, by delivering content you will find relevant and interesting	The collection of this personal data is necessary for the running of the Website and the provision of the Company services. Therefore, it is necessary since otherwise the content of our Website and our services could not be provided.	a.   Information collected when accessing the Website from a computer: your IP address; browser type; For more information please visit our Cookie Policy b.   If you access the Website from a mobile device: unique device identifier assigned to that device; For more information please visit our Cookie Policy

5.2.   It is not mandatory to provide us with your personal data. However, should you choose not to provide us with your personal data some of the Website's functionalities may be unavailable for your use (for example, you will not be able to send any questions or comments to us through the contact form if you do not include all required contact information).

5.3.   We are processing your personal data for direct marketing purposes or in order to enrol you in our marketing promotions based on your explicit, specific, informed and freely given consent which is obtained through a consent form which is made available to you when interacting with us. Every direct marketing message we send you includes an unsubscribe option which you can use to let us know that you no longer wish to receive such marketing communications from us. You have the right to withdraw your consent at any time, without any cost. Please consider that withdrawing your consent does not affect the lawfulness of the processing before such withdrawal. You can unsubscribe at any time without having to provide any reason and free of charge by accessing the link provided in any marketing message received from us or by sending a letter at the following address: 21, Aleea Fizicienilor Street, 1F block, 2nd stair, 4th floor, flat 27, District 3, Bucharest, Romania.

6.   HOW DO WE PROCESS YOUR PERSONAL DATA?

6.1.   With regard to the above mentioned purposes, the personal data is processed through both electronic and manual means, and is protected through adequate security measures. With this regards, although the Company uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification, it cannot guarantee that all possible cyber-risks can be excluded.

7.   WHO HAS ACCESS TO YOUR PERSONAL DATA?

7.1.   For purposes consistent with those at Section 5 of this Privacy Policy, the Company may share your personal data to the following categories of recipients located within or outside the European Union, in compliance and within the limits of the provisions of Section 8 below:

7.1.1.   Third parties service providers entrusted with processing activities and duly appointed as processors, for example: cloud service providers, companies that provide IT services, experts and consultants.

7.2.   A complete list of the data processors appointed by the Company may be requested by contacting us at [email protected]

8.   IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

8.1.   Your personal data will not be transferred to countries within and outside the European Economic Area (EEA). However, if such transfer will occur in the future, we will always make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data.

9.   PERSONAL DATA RETENTION

9.1.   We will retain your personal data only for the period necessary to fulfil the purposes for which the personal data was collected as outlined in this Privacy Policy. In any case, personal data collected for the purposes mentioned at Section 5 of this Privacy Policy is retained for the time necessary to provide you access to the Website or to grant you the provision of the Company services plus the length of any applicable statute of limitations following the termination of any Company services.

9.2.   At the end of the retention period your personal data will be either cancelled, anonymized or aggregated.

10.   WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?

10.1.   In relation to your personal data, you may request access to your personal data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your personal data, objection to the processing of your data, data portability and various information in relation to any automated decision making and profiling. You may also exercise a right to complain to the Romanian supervisory authority. More information about each of these rights can be found by referring to the table set out further below.

10.2.   To exercise your rights you may contact us as set out in Section 11. Please note the following if you do wish to exercise these rights:

10.2.1.   Identity. We take the confidentiality of all records containing personal data seriously, and reserve the right to ask you for proof of your identity if you make a request in respect of such records.

10.2.2.   Fees. We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, respective repetitive or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.

10.2.3.   Timescales. We aim to respond to any valid requests within one (1) month unless it is particularly complicated or you have made several requests, in which case we may extend that period by two further months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly.

10.2.4.   Third Party Rights. We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects.

Right	What this means
Access	You can ask us to: confirm whether we are processing your personal data; give you a copy of that data; provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making or profiling, to the extent that information has not already been provided to you in this Policy.
Rectification	You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it.
Erasure	You can ask us to erase your personal data, but only where: it is no longer needed for the purposes for which it was collected or otherwise processed you have withdrawn your consent (where the data processing was based on consent) and there is no other legal ground for the processing; following a successful right to object (see 'Objection' below); it has been processed unlawfully; to comply with a legal obligation to which the Company is subject. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: for compliance with a legal obligation; for the establishment, exercise or defence of legal claims; There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
Restriction	You can ask us to restrict (i.e. keep but not use) your personal data, but only where: its accuracy is contested (see Rectification), to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased and request the restriction of its use instead; it is no longer needed for the purposes for which it was collected, but you require it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding legitimate grounds is pending. We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; to protect the rights of another natural or legal person.
Portability	You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller, but in each case only where: the processing is based on your consent or on the performance of a contract with you; the processing is carried out by automated means.
Objection	You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Supervisory Authority	You have a right to lodge a complaint with The National Supervisory Authority For Personal Data Processing (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal). We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

11.   UPDATE TO THIS PRIVACY POLICY

The Company may modify or update this Privacy Policy also following different interpretations, decisions, opinions and orders relating to the GDPR. Please look at the effective date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any updates to this Privacy Policy will be posted in the form of a revised Privacy Policy on the Website. If we make material changes to this Privacy Policy that expand our rights to use the personal data we have already collected from you, we will notify you and provide you with a choice about our future use of the personal data.

12.   CONTACT US

You can contact us for all issues arising from this Policy, including requests to exercise data subject rights, at [email protected] or 21, Aleea Fizicienilor Street, 1F block, 2nd stair, 4th floor, flat 27, District 3, Bucharest, Romania.
If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible.